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Cabrillo-Santa Ynez 115 kV Reconductoring Project Mitigation Monitoring, Compliance, and Reporting Program Prepared for: California Public Utilities Commission 505 Van Ness Avenue San Francisco, California 94102 Prepared by: RMT Inc. 4 West Fourth Avenue, Suite 303 San Mateo, California 94402

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Page 1: Cabrillo-Santa Ynez 115 kV Reconductoring · PDF fileCabrillo-Santa Ynez 115 kV Reconductoring Project Mitigation Monitoring, Compliance, and Reporting Program Prepared for: California

Cabrillo-Santa Ynez 115 kV Reconductoring Project

Mitigation Monitoring, Compliance, and Reporting Program

Prepared for: California Public Utilities Commission 505 Van Ness Avenue San Francisco, California 94102 Prepared by: RMT Inc. 4 West Fourth Avenue, Suite 303 San Mateo, California 94402

Page 2: Cabrillo-Santa Ynez 115 kV Reconductoring · PDF fileCabrillo-Santa Ynez 115 kV Reconductoring Project Mitigation Monitoring, Compliance, and Reporting Program Prepared for: California
Page 3: Cabrillo-Santa Ynez 115 kV Reconductoring · PDF fileCabrillo-Santa Ynez 115 kV Reconductoring Project Mitigation Monitoring, Compliance, and Reporting Program Prepared for: California

Cabrillo-Santa Ynez 115 kV Reconductoring Project i

June 2010

Table of Contents Chapter 1: Introduction ............................................................................................................................. 1-1

1.1 Authority and Purpose of the Program ................................................................................... 1-1

1.2 Program Adoption Process ........................................................................................................ 1-2

1.3 Project Description ...................................................................................................................... 1-2

1.3.1 Project OVerview ................................................................................................................ 1-2

1.3.2 Construction Components ................................................................................................. 1-3

1.3.3 Project Documents .............................................................................................................. 1-4

1.4 Agency Jurisdiction ..................................................................................................................... 1-5

Chapter 2: Roles and Responsibilities ................................................................................................... 2-1

2.1 Organization Overview .............................................................................................................. 2-1

2.1.1 PG&E Project Construction Manager ............................................................................... 2-1

2.1.2 PG&E Construction Management .................................................................................... 2-1

2.1.3 PG&E Project Environmental Manager ........................................................................... 2-1

2.1.4 CPUC Project Manager ....................................................................................................... 2-3

2.1.5 CPUC Third-Party Monitors .............................................................................................. 2-3

2.1.6 PG&E Environmental Monitors ........................................................................................ 2-3

2.1.7 Construction Personnel ...................................................................................................... 2-3

2.1.8 Mitigation Monitoring Program Contact List ................................................................. 2-4

2.2 Responsibilities ............................................................................................................................ 2-4

2.2.1 Monitoring............................................................................................................................ 2-4

2.2.2 Enforcement ......................................................................................................................... 2-4

2.2.3 Mitigation Compliance ....................................................................................................... 2-5

2.3 Communication ........................................................................................................................... 2-5

2.3.1 Pre-construction Kick-off Meeting .................................................................................... 2-6

2.3.2 Progress Meetings ............................................................................................................... 2-6

2.3.3 Daily Communication ........................................................................................................ 2-6

2.3.4 Communicating Compliance Issues ................................................................................. 2-7

2.3.5 Coordination with Other Agencies ................................................................................... 2-7

2.3.6 Dispute Resolution .............................................................................................................. 2-7

Chapter 3: Environmental Compliance and Field Procedures ........................................................... 3-1

3.1 Mitigation Measures Compliance and Reporting .................................................................. 3-1

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TABLE OF CONTENTS

ii Mitigation Monitoring, Compliance, and Reporting Program

3.1.1 Pre-Construction Compliance Verification ...................................................................... 3-1

3.1.2 Notice to Proceed Procedures ............................................................................................ 3-1

3.1.3 Compliance Verification ..................................................................................................... 3-3

3.1.4 Compliance Reporting ........................................................................................................ 3-3

3.1.5 Compliance Levels .............................................................................................................. 3-3

3.2 Project Changes ............................................................................................................................ 3-4

3.2.1 Variance Procedure ............................................................................................................. 3-4

3.2.2 Temporary Extra Work Space Procedures ....................................................................... 3-5

3.3 Records Management.................................................................................................................. 3-6

3.4 Public Access to Records ............................................................................................................ 3-6

Chapter 4: Mitigation Monitoring Program Table ............................................................................... 4-1

4.1 Using the Table ............................................................................................................................ 4-1

4.2 Effectiveness Review ................................................................................................................... 4-1

Appendix A: Project Segment Maps

Appendix B: Project Contact List

Appendix C: Communication Protocol Summary

Appendix D: Variance Request Form

Appendix E: Temporary Extra Work Space Form

Appendix F: Mitigation Monitoring Program Table

LIST OF TABLES

Table 1.3-1: Proposed Construction Schedule ........................................................................................ 1-3

Table 1.4-1: Permits and Approvals Necessary for the Proposed Project ........................................... 1-5

Table 2.2-1: Required On-Site Monitoring ............................................................................................... 2-5

LIST OF FIGURES

Figure 2.1-1: Project Management Organizational Chart ...................................................................... 2-2

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Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-1

June 2010

Chapter 1: Introduction

The Final Initial Study/Mitigated Negative Declaration (IS/MND) for the Cabrillo-Santa Ynez 115

kV Reconductoring Project, as adopted by the California Public Utilities Commission (CPUC) on

May 6, 2010, includes procedures for preparing and implementing a Mitigation Monitoring,

Compliance, and Reporting Plan (MMCRP) to ensure compliance with mitigation measures

approved in the Final IS/MND. Chapter 4 of the Final IS/MND provides the recommended

framework for the implementation of the MMCRP by the CEQA Lead Agency, the CPUC, and

describes the roles and responsibilities of government agencies in implementing and enforcing

adopted mitigation measures. This MMCRP includes the information provided in Chapter 4, as

well as specific protocols to be followed prior to and during construction by CPUC third-party

environmental monitors (CPUC EMs) and Pacific Gas & Electric (PG&E) project staff. RMT Inc.

(RMT) will be providing CPUC’s EMs.

The project’s MMCRP includes direct participation and commitment from PG&E and CPUC EMs.

The success of the program depends on the project management staff, monitors, and construction

contractor personnel. The goal of the MMCRP is to provide a clear understanding of the project’s

organization, established lines of communication, and documentation and report compliance

measures with all of the mitigation measures.

The MMCRP was developed to provide guidelines and standardize procedures for environmental

compliance on the project. The procedures have been developed in coordination with PG&E,

CPUC, and RMT to help define the reporting relationships, provide detailed information about the

roles and responsibilities of the project’s environmental compliance team members, define

compliance reporting procedures, and to establish a communication protocol.

1.1 Authority and Purpose of the Program

The California Public Utilities Code, in numerous places, confers authority upon the CPUC to

regulate the terms of service and the safety, practices and equipment of utilities subject to its

jurisdiction. It is the standard practice of the CPUC, pursuant to its statutory responsibility to

protect the environment, to require that mitigation measures stipulated as conditions of approval

are implemented properly, monitored, and reported on. In 1989, this requirement was codified

statewide as Section 21081.6 of the Public Resources Code. Section 21081.6 requires a public agency

to adopt a Mitigation Monitoring, Compliance, and Reporting Program when it approves a project

that is subject to preparation of an IS/MND. CEQA Guidelines Section 15097 was added in 1999 to

further clarify agency requirements for mitigation monitoring or reporting. The CPUC views the

MMCRP as a working guide to facilitate not only the implementation of mitigation measures by

the project proponent, but also the monitoring, compliance, and reporting activities of the CPUC

and any monitors it may designate.

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CHAPTER 1: INTRODUCTION

1-2 Mitigation Monitoring, Compliance, and Reporting Program

1.2 Program Adoption Process

The mitigation measures proposed in the Final IS/MND and the framework for this MMCRP, as

described in Chapter 4 of the Final IS/MND, were approved by the CPUC on May 6, 2010, (10-05-

006). A draft version of the MMP was distributed to PG&E, CPUC, and RMT for review and

comment.

1.3 Project Description

1.3.1 PROJECT OVERVIEW The 14.6-mile Cabrillo-Santa Ynez 115 kV power line connects Cabrillo Substation to Santa Ynez

Switching Station, and comprises one segment of an approximately 80-mile 115 kV transmission

loop for the Lompoc-Santa Ynez areas. This loop serves over 71,000 customers in the general area

between Santa Maria, Lompoc, Santa Ynez, and Solvang.

This project would require the following to reduce instances of line failure:

Replacing the existing single-circuit 4/0 AAC with a 715 Multi-Chip Model (MCM), non-

specular AAC on approximately 14.1 miles of an existing 14.6-mile power line

Replacing approximately 125 existing wood poles (currently holding the 4/0 AAC) with

new light-duty steel poles along the power line route

The existing segment of the power line between Cabrillo Substation and Santa Ynez Switching

Station was upgraded from 70 kV to 115 kV with distribution-style dead-end shoes in 1988. The

upgrade cost-effectively provided strength to meet tensioning requirements for this line.

Subsequent investigation has determined this style of distribution design causes excessive bending

of the conductor. The sharp bends, when exposed to the frequent local winds, create cyclic fatigue

in the conductor, and resulting in increased failures.

The coastal climate produces foggy and windy conditions throughout the year, which have

contributed to the accelerated deterioration of the existing conductors and associated hardware,

causing frequent failures. The project would replace aging wood poles with new light-duty steel

poles, and outdated or deteriorated hardware with an upgraded conductor (a heavier 715 MCM

AAC), new insulators, and other required hardware along 14.1 miles of the existing power line.

The remainder of the 80-mile power line extending into Cabrillo Substation does not require

reconductoring because it currently uses the new MCM AAC. Average distances between poles

(i.e., spans) are anticipated to vary between 350 and 780 feet, with a maximum span length

between two poles of less than 1,500 feet.

Conductors and Other Hardware

The existing bare aluminum conductor would be replaced with a new 715 aluminum, non-

specular conductor. Insulators along the entire 14.6-mile line would also be replaced during

construction. The approximate distance from the ground to the lowest conductor would follow

G.O. 95 requirements. All existing communication lines and 12 kV distribution underbuilds that

are collocated with the existing conductor would be moved to the new poles.

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CHAPTER 1: INTRODUCTION

Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-3

June 2010

Schedule

The project is estimated to begin construction in June 2010 and last approximately 15 months, with

a completion date of August 2011. The Cabrillo-Santa Ynez 115 kV power line would not be

removed from service during the summer because of high seasonal demands. The majority of pole

installation, line reconductoring, and pole removal is expected to be performed throughout the

year with the majority of activities occurring outside the summer months of June, July, and

August. Reconductoring would begin when new poles have been installed along an

approximately 1-mile distance (i.e., approximate length of new conductor reel).The proposed

schedule is presented in Table 1.3-1.

1.3.2 CONSTRUCTION COMPONENTS Components of the proposed project are described in detail below. Segment maps illustrating the

locations of these components are found in Appendix A.

Power Line

The existing line is a 115 kV, single-circuit, 14.6 mile long power line. The proposed

reconductoring on approximately 14.1 miles of this line would not change the line capacity or

length. Other lines, equipment, and utilities, such as communications lines that are collocated on

the existing poles, would be transferred to the new poles.

Poles

The project includes replacing 125 wood poles along the route with new direct-buried, light-duty

steel poles designed to meet General Order 95 (G.O. 95) clearance requirements for the new 715

MCM AAC. Direct-buried poles would not require the installation of foundations. New steel poles

Table 1.3-1: Proposed Construction Schedule

Project Activity Proposed Schedule

Final engineering completed October 2009

Begin acquiring temporary construction easements December 2009

Permit To Construct decision adopted and effective May 6, 2010

Acquire required permits June 2010

ROW and property acquisition Not anticipated; if needed, March 2010

Construction begins: access road re-establishment and pole

installation

June 2010

Pole installation, reconductoring (as pole installation and line

clearances permit), and pole removal

July 2010 through August 2011,

as schedule constraints allow

Project operational August 2011

Cleanup September 2011

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CHAPTER 1: INTRODUCTION

1-4 Mitigation Monitoring, Compliance, and Reporting Program

would have a surface treatment designed to mimic the appearance of natural weathering similar to

that of the current wood poles. Steel poles also would provide superior protection from wildfires,

rotting, and woodpecker damage compared to the existing wood poles. The new poles would be

installed consistent with PG&E standard raptor-safe design criteria, which provide 8.5 feet of

clearance between conductors and lower voltage lines located underneath the transmission line

(i.e., underbuild). Triangular raptor perch deterrents would be installed per PG&E guidelines in

areas supporting 12 kV underbuilds. Eight existing wood poles along the route (Poles 1 through 6,

11, and 17) would not be replaced with new steel poles. These poles were recently replaced during

routine or emergency maintenance and are in good condition. Insulator replacement and

reconductoring activities would still be performed in these areas.

The new poles are designed to accommodate sway associated with the new conductor and

suspension-style insulators. The new poles would be buried deeper (11 to 13.5 feet) than existing

poles (7 to 10 feet). Aboveground pole heights would not change significantly, ranging from 49 to

64 feet, except at two locations (i.e., at the SR 246 crossing and in the proximity of a residential

development on the east end of the power line), where poles would be 5 to 12 feet taller than

existing poles to provide adequate ground clearance and reduce electromagnetic fields (EMF) near

residences. Average distances between poles (i.e., spans) are anticipated to vary between 350 and

780 feet, with a maximum span length between two poles of less than 1,500 feet.

Conductors and Other Hardware

The existing bare aluminum conductor (4/0 AAC, seven strand, 0.52 inch in diameter) would be

replaced with a new 715 aluminum, non-specular conductor (715 MCM AAC, 0.97 inch in

diameter).

To optimize the efficiency of operation and maintenance activities, insulators along the entire 14.6-

mile line would also be replaced during construction, creating a consistent age for hardware along

the power line. All existing communication lines and 12 kV distribution underbuilds that are

collocated with the existing conductor would be moved to the new poles.

The approximate distance from the ground to the lowest conductor would follow G.O. 95

requirements:

Thoroughfares traversed by vehicles: 30 feet minimum

Water crossings less than 20 acres: 27 feet minimum

Highway crossings (e.g., SR 246): 30 feet minimum

1.3.3 PROJECT DOCUMENTS

The MMCRP is intended to provide pertinent information necessary to successfully implement the

MMP during construction. The mitigation measures and Applicant Proposed Measures (APM)

listed in Section 4.3 are presented in Chapter 4 of the Final IS/MND. Detailed discussions on the

actions required for each mitigation measure and APM are provided in these sections as well. In

addition to the Final IS/MND, construction activities must be conducted in accordance with the

requirements stipulated in the following documents:

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CHAPTER 1: INTRODUCTION

Cabrillo-Santa Ynez 115 kV Reconductoring Project 1-5

June 2010

Stormwater Pollution Prevention Plan (SWPPP), including an Erosion Control and

Sediment Transport Plan (ECSTP)

Worker Environmental Awareness Program (including biological and cultural

resources)

Avian Protection Plan

Hazardous Substance Control and Emergency Response Plan

Fire Prevention and Response Plan

Traffic Management Plan (TMP)

Health and Safety Plan

1.4 Agency Jurisdiction

In addition to the CPUC, several local, state, and federal agencies have jurisdiction over lands that

are crossed by the project route. The CPUC, as the lead agency, is responsible for ensuring that

mitigation measures reviewed and approved by jurisdictional agencies during the Draft IS/MND

process are implemented throughout construction. However, jurisdictional agencies may visit the

project site from time to time and request information regarding the status of a mitigation

measure. In addition, PG&E is required to submit survey results to the US Fish and Wildlife

Service and the California Department of Fish and Game, and consult with these agencies when

project changes affect the condition of their permit. PG&E is responsible for satisfying requests

from jurisdictional agencies, and will notify and copy the CPUC on all correspondences related to

final approvals and permits for the project if the CPUC is not otherwise copied on the

correspondence. Additional information on communication protocols is presented in Section 2.3

below. Table 1.4-1 lists jurisdictional agencies, purpose of consultation, and required permits

associated with the project:

Table 1.4-1: Permits and Approvals Necessary for the Proposed Project

Permit, Approval, or Exemption Purpose Regulating Agency

Federal

Section 7 Consultation: Incidental

Take Permit

Endangered Species Act compliance U.S. Fish and Wildlife Service

Clean Water Act 404 Nationwide

Permit

Discharge of dredged and fill

material into waters of the United

States

U.S. Army Corps of Engineers

State

Consistency Determination Compliance with Section 2080.1 of

the California Endangered Species

Act

California Department of Fish

and Game

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CHAPTER 1: INTRODUCTION

1-6 Mitigation Monitoring, Compliance, and Reporting Program

Table 1.4-1 (Continued): Permits and Approvals Necessary for the Proposed Project

Permit, Approval, or Exemption Purpose Regulating Agency

State

Storm Water Pollution

Prevention Plan; enrollment

under General Construction

National Pollution Discharge

Elimination System permit

Road grading and ground

disturbance for pole installation

Central Coast Regional Water

Quality Control Board

Section 401 certification Discharge of dredged and fill

material into waters of the United

States.

Central Coast Regional Water

Quality Control Board

Encroachment Permits For any work to take place within

ROW for US 101, SR 1, and SR 246

California Department of

Transportation

Local

Traffic Control Permit Required for any work within the

ROW for County roadways

Santa Barbara County

Department of Public Works

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Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-1

June 2010

Chapter 2: Roles and Responsibilities

This section describes the roles and responsibilities of key project personnel with respect to the

MMCRP. Figure 2.1-1 provides an organizational chart of project members responsible for

implementing the MMCRP and their relationship to other staff working on the project. The

organization chart also establishes preliminary lines of communication between the project team

members.

2.1 Organization Overview

2.1.1 PG&E PROJECT CONSTRUCTION MANAGER

PG&E’s Project Construction Manager (Lee Ellis) provides the overall direction, management,

leadership, and corporate coordination for the construction project. The Project Construction

Manager will be based in PG&E’s San Luis Obispo office, 406 Higuera St., San Luis Obispo for the

duration of construction. The Project Construction Manager’s responsibilities related to the

environmental program include, but are not limited to:

Coordinate between engineering, construction management, and environmental staff;

Provide leadership by integrating environmental responsibilities into all levels of the

project organization;

Ensure compliance with project policies, guidelines, and procedures; and

Communicate project activities, schedules, and public relation issues to the project team.

2.1.2 PG&E CONSTRUCTION MANAGEMENT The Construction Management (TBD) provides support to the Project Construction Manager and

oversees activities of construction staff. The Construction Management will be based out of

PG&E’s Templeton Service Center, 160 Cow Meadow Place, Templeton , but will also typically be

available in the field on a daily basis. Specific responsibilities of the Construction Management

include, but are not limited to:

Ensure compliance with company specifications, permit conditions, construction

contracts, and applicable codes;

Notify Environmental Monitors of project and schedule changes;

Work with Environmental Monitors to evaluate and improve the implementation of the

MMCRP, as construction progresses; and

Regularly facilitate project field meetings.

2.1.3 PG&E PROJECT ENVIRONMENTAL MANAGER PG&E’s Project Environmental Manager (Sam Danner) is responsible for providing the

appropriate level of resources for successful implementation of the MMCRP. The Project

Environmental Manager is responsible for directing development and implementation of

preconstruction environmental planning, permitting and compliance activities, environmental

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CHAPTER 2: ROLES AND RESPONSIBILITIES

2-2 Mitigation Monitoring, Compliance, and Reporting Program

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CHAPTER 2: ROLES AND RESPONSIBILITIES

Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-3

June 2010

inspection program, and environmental training. The Project Environmental Manager is also

responsible for ensuring compliance with the Section 7 Consultation and 2080.1 Consistency

Determination. The Project Environmental Manager will be based out of PG&E’s San Luis Obispo

Service Center.

2.1.4 CPUC PROJECT MANAGER The CPUC Project Manager will determine the effectiveness of the MMCRP based on the success

criteria included in the mitigation monitoring table. The CPUC will delegate monitoring and

reporting responsibilities to third-party monitors during construction, and will oversee their work

through review of daily and weekly status reports. The CPUC Project Manager will be notified of

noncompliance situations and may suggest measures to help resolve the issue(s). All variance

requests will be submitted to the CPUC Project Manager for review and approval.

2.1.5 CPUC THIRD-PARTY MONITORS

The CPUC will delegate daily monitoring and reporting responsibilities to a third-party

monitoring program. The number of third-party monitors (CPUC EMs) and frequency of site

inspections will depend on the number of concurrent construction activities and their locations.

The CPUC EMs will report directly to the CPUC Monitoring Project Director (CPUC Monitoring

PD) and Project Manager (CPUC Monitoring PM) who will oversee the day-to-day monitoring

activities of the EMs, as well as determine the appropriate level of inspection frequency. The

overall monitoring program will be administered under the direction and oversight of the CPUC

Project Manager. CPUC EMs will be an integral part of the project team, and will stay apprised of

construction activities, schedule changes and construction progress. The CPUC EMs will

document compliance through weekly reports and use of a mitigation measure tracking table.

2.1.6 PG&E ENVIRONMENTAL MONITORS

The PG&E monitoring team will include a Environmental Lead who will coordinate the activities

of the lead, biological, paleontological, cultural, and hazardous materials monitors, as needed, to

comply with each mitigation measure. PG&E Environmental Monitors will work closely with

construction personnel to ensure pre-construction surveys are completed and mitigation measures

are implemented correctly. PG&E Environmental Monitors will also work closely with the CPUC

EMs to determine the effectiveness of mitigation measures, and whether adjustments are needed

to provide adequate protection of sensitive resources.

2.1.7 CONSTRUCTION PERSONNEL The PG&E construction staff and contractor staff have significant responsibilities for compliance

with the environmental requirements of the project. The Construction Manager and contractor(s)

will be responsible for incorporating all project environmental requirements into their day-to-day

construction activities. Key environmental responsibilities for the Construction Manager and

Contractor(s) staff include, but are not limited to:

Verify that all construction workers attend the project’s environmental training program

prior to beginning work on the ROW;

Review and understand the environmental requirements;

Implement environmental protection requirements and conditions during construction;

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CHAPTER 2: ROLES AND RESPONSIBILITIES

2-4 Mitigation Monitoring, Compliance, and Reporting Program

Maintain compliance with project requirements; and

Respond to PG&E Environmental Monitor’s requests during construction.

2.1.8 MITIGATION MONITORING PROGRAM CONTACT LIST

A project contact list is included as Appendix B. This contact list includes the names of PG&E and

CPUC monitors, project managers, supervisory staff, and other members of the project team. The

list also includes phone numbers, fax numbers, and e-mail addresses where project members can

be reached during construction. The contact list will be updated periodically and redistributed to

the project team.

2.2 Responsibilities

2.2.1 MONITORING

As the lead agency under CEQA, the CPUC is required to monitor this project to ensure that the

required mitigation measures and APMs are implemented. The CPUC is responsible for ensuring

full compliance with the provisions of this monitoring program and has primary responsibility for

implementation of the monitoring program. As stated above, the CPUC has delegated monitoring

responsibilities to a third-party monitoring program. The CPUC EMs will be in field on a regular

basis, particularly when construction activities have the potential to impact a sensitive resource.

Responsible agencies, such as the USFWS, CDFG, and RWQCB may also elect to monitor

construction or conduct a site visit during construction.

Several mitigation measures require a qualified specialty monitor during construction. The

mitigation measures presented in Table 2.2-1 require that PG&E provides an on-site monitor.

PG&E may elect to have one or more full-time environmental monitors on-site on a daily basis to

coordinate specialty monitors, and to assist construction crews with interpreting mitigation

measures and correcting compliance problems in a timely manner. Environmental monitors would

also provide environmental training, as required, as new workers arrive on the project.

2.2.2 ENFORCEMENT The CPUC is responsible for enforcing the procedures adopted for monitoring through the CPUC

EMs assigned to each segment. The CPUC EMs shall note problems with monitoring, notify

designated project members, and report the problems to the CPUC Monitoring PM and PD, who

will then report problems to the CPUC Project Manager. The CPUC has the authority to stop or

redirect any construction activity associated with the Cabrillo-Santa Ynez 115 kV Reconductoring

Project, assuming it is safe to do so, if an activity poses an imminent threat or puts a sensitive

resource at undue risk beyond that already permitted (e.g., stopping a clearing crew from

unknowingly cutting coastal sage scrub in an exclusion area). The CPUC has assigned this

authority to the CPUC EMs in the field.

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CHAPTER 2: ROLES AND RESPONSIBILITIES

Cabrillo-Santa Ynez 115 kV Reconductoring Project 2-5

June 2010

Table 2.2-1: Required On-Site Monitoring

Mitigation Measure/

Applicant Proposed

Measure Number

Resource Monitor Project Area

MM AQ-1 Air Quality: Dust

Control Measure

General All, as needed

MM Bio-2 Sensitive Biological

Resources

Biological All, daily or as required in permits

MM Bio-5 Sensitive Plant

Species

Biological All, marking populations prior to

construction

MM Bio-6 Sensitive Amphibian

species

Biological Pull Site P4, P9, P10, P12, and P15;

Poles 11, 31, 33, 34, 48, 49, 68, 69, 70, 71,

72, 81, 82, 85, 86, 89, 90, 91, 112, 113,

114, and 115 68, 69, 70, 71, 114, 115, or

as otherwise required in permits

MM Bio-9 Sensitive Avian

Species

Biological Pull Site P1; Poles 4, 5, and 6

MM Bio-10 Active Burrowing

Owl Nests

Biological As needed where identified

MM Bio-12 Active Migratory

Bird or Raptor Nest

Biological As needed where identified

2.2.3 MITIGATION COMPLIANCE

PG&E is responsible for successfully implementing all the adopted mitigation measures in the

MMCRP. The MMCRP contains criteria that define whether mitigation is successful. Standards for

successful mitigation are also implicit in many mitigation measures that include such

requirements as obtaining permits or avoiding a specific impact entirely. Additional mitigation

success thresholds may be imposed by applicable agencies with jurisdiction through the permit

process.

PG&E shall inform the CPUC and its monitors, in writing, of any mitigation measures that are not

or cannot be successfully implemented. The CPUC, in coordination with its monitors, will assess

whether alternative mitigation is appropriate, and determine with PG&E the subsequent actions

required. If the measures are agency permit requirements, then the agency issuing the permit may

determine the appropriate action.

2.3 Communication

Communication is a critical component of a successful environmental compliance program. In

order to avoid project delays and possible shut-downs, environmental and construction

representatives must interact regularly and maintain professional, responsive communications at

all times. Similarly, PG&E representatives must coordinate closely with CPUC EMs to address and

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CHAPTER 2: ROLES AND RESPONSIBILITIES

2-6 Mitigation Monitoring, Compliance, and Reporting Program

resolve issues in a timely manner. Section 2.3 of this MMCRP provides a communication protocol

to accurately disseminate information pertaining to on-going surveys and mitigation measures,

construction activities, contractors, and planned or upcoming work to all levels of the project.

Appendix C includes a communication protocol summary for use as quick reference, and to

supplement information provided in Section 2.3.

2.3.1 PRE-CONSTRUCTION KICK-OFF MEETING A pre-construction meeting was held on May 18, 2010 with the CPUC and PG&E team to review

the MMCRP and mutually agree upon the project’s communication protocol. Based on discussion

at the meeting and input from each party, Section 2 of this document was finalized and

incorporated into the MMCRP.

2.3.2 PROGRESS MEETINGS PG&E may request CPUC’s EM(s) to participate in regular field meetings to help resolve any issue

that may have arisen during the previous period and anticipate the upcoming activities.

Alternatively, PG&E or CPUC’s EM(s) may recommend a separate meeting to discuss mitigation,

variance requests, or other project related issues.

In addition to the progress meetings conducted at the field level, the PG&E Project Manager,

PG&E Construction Manager, PG&E EM, and the CPUC Monitoring PD and/or CPUC Project

Manager may participate in a weekly teleconference call to discuss project status.

2.3.3 DAILY COMMUNICATION Many of the issues that come up during construction can be resolved in the field through regular

communication between CPUC EMs, PG&E, and construction supervisors and contractors. Field

staff will be equipped with cell phones and available to receive phone calls at all times during

construction. A project contact list is included in Appendix B. The organization chart depicted in

Section 2.0 generally shows the lines of communication for use during construction. Additional

guidelines to ensure effective communication in the field are summarized below.

CPUC EM

The CPUC EM’s primary point of contact in the field is PG&E’s Lead Environmental Monitor. The

CPUC EM will contact PG&E’s Lead Environmental Monitor, if an activity is observed that

conflicts with one or more of the mitigation measures, to correct the situation. If the CPUC EM

cannot immediately reach PG&E’s Lead Environmental Monitor, then the Environmental Lead or

PG&E Project Environmental Manager will be contacted to address the problem. Similarly, the

CPUC EM will contact PG&E’s Lead Environmental Monitor for information on where

construction crews are working, the status of mitigation measures, and schedule forecasts. The

CPUC EM may discuss construction procedures directly with the construction contractors;

however, PG&E may require that their contractors defer questions to an onsite PG&E

representative. In all cases, the CPUC EM will contact the designated PG&E representative if a

problem is noted that requires action from the contractor.

The CPUC EM will not direct the contractor; however, the EM has the authority to stop or redirect

an on-going activity, assuming it is safe to do so, if an activity poses an imminent threat or puts a

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sensitive resource at undue risk beyond that already permitted (e.g., stopping a clearing crew from

unknowingly cutting coastal sage scrub in an exclusion area).

PG&E

PG&E will provide the CPUC Monitoring team with a list of construction monitoring personnel

and construction supervisory staff to contact regarding compliance issues. The contact list will

include each person’s title and responsibility, and will be updated as new project personnel are

assigned to the project and redistributed as necessary.

PG&E will prepare and distribute a weekly environmental compliance status report for

distribution to key project members, including the CPUC.

Any questions regarding the status of mitigation measures will be directed to the PG&E

Environmental Lead. The weekly environmental compliance status report will also be a tool to

keep all parties informed of construction progress and schedule changes.

2.3.4 COMMUNICATING COMPLIANCE ISSUES Section 3.1.2 below describes procedures to communicate concerns, incidents, and non-

compliances identified by the CPUC EMs during site inspections.

2.3.5 COORDINATION WITH OTHER AGENCIES

As discussed in Section 1.4, several local, state, and federal agencies have jurisdiction over portions

of the project. In addition, many of the mitigation measures were derived from specific permit

conditions or agency input. PG&E is responsible for contacting resource agencies and notifying

them of issues regarding their jurisdiction. The CPUC Monitoring team may request copies of

email correspondences, phone logs, or other documentation between PG&E and resource agencies

to avoid direct involvement from CPUC Monitoring PD or PM. However, if there is an unresolved

issue regarding compliance with a mitigation measure or permit requirement under the

jurisdiction of a resource agency, the CPUC Monitoring PD or PM may elect to contact the agency

with PG&E to discuss resolution, but only after having given PG&E sufficient time to address the

issue themselves. The CPUC Monitoring PD or PM will coordinate with PG&E prior to making

this call and provide PG&E with an opportunity to participate in the call.

2.3.6 DISPUTE RESOLUTION It is expected that the MMCRP will reduce or eliminate many potential disputes; however, even

with the best preparation, disputes may occur.

Issues should be first addressed at the field level informally between the CPUC EMs and

PG&E’s Environmental Monitors or Environmental Lead or at the regular progress meetings.

Questions may be raised to the PG&E Project Environmental Manager and the Environmental

Lead or PG&E Project Construction Manager. Should the issue persist or not be resolved at these

levels, the following procedures will be used.

Step 1 Disputes unresolved in the field and complaints (including those of the public) should be

directed to the CPUC Project Manager for resolution. The Project Manager will attempt to

resolve the dispute informally. Should this informal process fail, the CPUC Project Manager

will inform PG&E prior to initiating Step 2.

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Step 2 Should this informal process in the field fail, the CPUC Project Manager may issue a formal

letter requiring corrective actions to address the unresolved or persistent deviations from

the Proposed Project or adopted Mitigation Monitoring Program.

Step 3 If a dispute or complaint regarding implementation or evaluation of the Program or

mitigation measures cannot be resolved informally or through a letter request, any affected

participant in the dispute or complaint may file a written “notice of dispute” with the

CPUC’s Executive Director. This notice should be filed in order to resolve the dispute in a

timely manner, with copies concurrently served on other affected participants. Within 10

days of receipt, the Executive Director or designee(s) shall meet or confer with the filer and

other affected participants to resolve the dispute. The Executive Director shall issue an

Executive Resolution describing his/her decision, and serve it on the filer and other affected

participants.

Step 4 If one or more of the affected parties is not satisfied with the decision as described in the

Resolution, such party(ies) may appeal it to the Commission via a procedure to be specified

by the Commission.

Parties may also seek review by the Commission through existing procedures specified in the

CPUC Rules of Practice and Procedure for formal and expedited dispute resolution, although a

good faith effort should first be made to use the foregoing procedure.

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Chapter 3: Environmental Compliance and Field Procedures

3.1 Mitigation Measures Compliance and Reporting

3.1.1 PRE-CONSTRUCTION COMPLIANCE VERIFICATION In addition to performing various surveys and studies prior to construction, PG&E is required, by

the terms of the mitigation measures and the permitting requirements of various other regulating

agencies, to prepare plans and obtain approval of these documents. Copies of this documentation

will be retained by the CPUC third-party monitors, and provided to the CPUC with all files at the

completion of the project. The required plans, surveys, studies, and other documentation that

must be completed by PG&E before construction are listed in the Mitigation Measure/Applicant

Proposed Measure tables in Section 4.3.

While these documents are being reviewed by the approving agencies, they are also reviewed by

the CPUC. Compliance with all pre-construction mitigation measures and APMs presented will be

verified prior to construction, and construction may not start on any segment before PG&E

receives a written Notice to Proceed (NTP) from the CPUC Project Manager.

The CPUC third-party monitors, including Project Management staff and the technical experts,

will review all mitigation plans and reports and provide comments where applicable. Resource

agencies will also be involved in the review of applicable plans and reports. Where the MND calls

for CPUC review and approval of a plan or document, comments on these documents will be

provided to PG&E For required local and State agency permitting/consultations, the CPUC third-

party monitors will track PG&E’s progress as it relates to PG&E’s construction plans and project

mitigation and permitting requirements. Based on PG&E’s construction plans, CPUC may

authorize construction to begin on a phased basis, and the CPUC third-party monitors will handle

pre-construction compliance review accordingly. CPUC may issue NTPs for construction of each

phase separately, as soon as pre-construction compliance is satisfactorily accomplished for that

phase.

IMPORTANT: The CPUC will not authorize construction to begin until all pre-construction

requirements are fulfilled as appropriate for a given phase. To save time, PG&E should identify

any extra work space needs required for each phase of construction prior to the start of active

construction, so that these locations and their use can be included in the NTP. Refer to Section

3.2.1.

3.1.2 NOTICE TO PROCEED PROCEDURES The CPUC Project Manager and all IS/MND team reviewers will ensure that the Notice to Proceed

(NTP) process is consistent with the adopted CEQA document. The NTP approval(s) shall

document that pre-construction mitigation measure requirements, including applicable surveys

and studies, and project permit requirements have been met. In consideration of linear or phased

projects, more than one NTP can be requested for the Project. Each NTP request would be

applicable to a defined aspect or segment of construction. Construction is defined as any

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mobilization activity which would move construction-related equipment and/or materials onto a

site. In some instances compliance with every requirement cannot be met prior to NTP issuance

and in such cases the NTP may be conditioned to define actions that will be undertaken and

documented prior to construction or prior to energizing the line.

Therefore, an NTP may be issued for a particular segment or project component upon compliance

with applicable mitigation measures and permits, and this process could occur in advance of

mitigation compliance for the entire project as a whole.

In general, an NTP request must include the following information:

A description of the work.

Detailed description of the segment location, including maps, photos, and/or other

supporting documents.

Verification that all mitigation measures and Applicant Proposed Measures are

implemented, or that they do not apply to the work covered by the NTP request.

Verification that all applicable permit conditions or requirements have been met for the

work covered by the NTP request.

In the case where some outstanding compliance items cannot be met prior to issuance of

the NTP, a request shall be submitted that outlines what submittals are outstanding, as

well as how they will be met and approved in a timely manner prior to construction.

Up-to-date biological resource surveys or a commitment to survey and submit results

prior to construction.

All applicable jurisdictional permits or agency approvals (if necessary).

Date of expected construction and duration of work.

CPUC/RMT will review the NTP request and pre-construction requirement submittals, in

accordance with the steps outlined below, to ensure that all of the information required to process

the approval is included.

1. PG&E submits NTP request.

2. CPUC/RMT will distribute the NTP request to the appropriate resource specialists and

reviewers to determine the completeness of the request, as applicable.

3. CPUC/RMT will also review and, if needed, will prepare a list of outstanding

requirements and where additional information or clarification is needed.

4. All questions and comments, as well as required additional information or clarifications,

will be sent to PG&E by CPUC/RMT in an e-mail.

5. PG&E will supply clarifications and/or additional information to be added to the NTP

request in a memo or letter format, along with responses addressing all comments and

questions forwarded by CPUC/RMT.

6. CPUC/RMT will complete a Compliance Status Table documenting compliance and any

outstanding requirements that can be made conditions of the NTP. If comments or

conditions are provided by CDFG, USFWS, Corps, and/or CCRWQCB, they will be

considered for incorporation into the NTP approval letter and compliance table.

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7. RMT will prepare the draft NTP approval letter, which will document the scope of

work, compliance with IS/MND mitigation requirements, and list outstanding

conditions.

8. CPUC will review the draft NTP approval letter, and send the approval and an updated

compliance table to PG&E.

Please note that variance requests can be submitted with the NTP request for incorporation into

the NTP (please see Section 3.2.1 for variance submittal requirements).

3.1.3 COMPLIANCE VERIFICATION The CPUC EMs will conduct routine site visits to determine compliance with the mitigation

measures. Site visits will be coordinated with PG&E; at a minimum, the EMs will verify with

PG&E that access can be safely granted. Supplemental information provided by PG&E, including

pre-construction submittals, survey reports, weekly reports, meeting notes, and agency

correspondences, will also be used to verify compliance.

3.1.4 COMPLIANCE REPORTING

The CPUC EMs will document observations along the ROW through the use of field notes and

digital photography. In addition, field inspection forms will be utilized in the field to document

compliance of specific crews, construction activities, or resource protection measures. The forms

will provide a standardized checklist to facilitate inspections, as well as list mitigation measures

that were verified during the site visit. Information gathered from the inspection forms and field

notes will be used to generate weekly status reports and update the status of mitigation measures

listed in Section 4.3.

3.1.5 COMPLIANCE LEVELS Observations of issues or concerns that do not rise to the level of a non-compliance event, but that

if left uncorrected or repeated could result in a non-compliance event, should be noted and

provided to PG&E. These observations or concerns could also include minor deviations from a

permit condition or mitigation measure that do not affect the effectiveness of the mitigation

measures. Examples could include a trash bin that needs emptying, substitution of a coir roll for a

silt fence in the SWPPP measures that provides equivalent protection, a clarification to the

interpretation of a measure, a worker who was stopped before entering an exclusion zone for

which he did not know the footprint. These are typically issues or concerns that are addressed and

resolved at the field level.

A construction activity that deviates from permit conditions or mitigation measures and puts a

resource at un-permitted risk, would be considered a non-compliance. A noncompliance may also

be issued if a mitigation measure is not implemented according to the timing restrictions listed in

the mitigation table. Examples of non-compliances include, but are not limited to the actions listed

below.

Use of staging areas or extra workspace not identified in the MND or approved for use

during construction

Encroachment into an exclusion zone or sensitive resource area designated for

avoidance

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Construction-related brush clearing outside the approved work limits

Construction-related grading, pole replacement, or line work without required

biological pre-construction surveys or a biological monitor onsite where and when

required

Improper installation of erosion or sediment control structures that cause unauthorized

release of sediments

Discharge of sediment laden pole hole water into a waterbody or storm drain

The CPUC EM will immediately notify the designated PG&E representative of a noncompliance

that requires immediate corrective action. A non-compliance memorandum will be sent to PG&E

by the CPUC Project Manager that outlines the incident, lists actions required to bring the activity

back into compliance, and provides a timeline for follow-up. If a construction activity or observed

resource protection measure only slightly deviates from project requirements and does not put a

resource at risk, the CPUC EM would instead issue an incident report to get the issue corrected.

Construction activities that could result in an incident report include, but are not limited to the

actions listed below.

Failure to properly maintain an erosion or sediment control structure, but the structure

remains functional

Use of an existing unapproved access road

Project personnel begin work on the ROW without proof of training

Work outside the approved work limits where the incident is within a previously

disturbed area, such as a gravel lot

Repeated incidents without addressing the issue may result in non-compliance.

3.2 Project Changes

At various times throughout the project, the need for extra workspace or additional access roads

may be identified. Similarly, changes to the project requirements (e.g., mitigation measures,

specifications, etc.) may be needed to facilitate construction or provide more effective protection of

resources. The project team should work together to find solutions when variations or adjustments

are necessary for specific field situations to avoid conflicts with adopted mitigation measures or

specifications.

3.2.1 VARIANCE PROCEDURE The CPUC Project Manager along with the CPUC Monitoring team will ensure that any variance

process or deviation from the procedures identified under the monitoring program is consistent

with CEQA requirements. No project variance will be approved by the CPUC if it creates new

significant impacts. A variance should be strictly limited to minor project changes that will not

trigger other permit requirements unless the appropriate agency has approved the change, that

does not increase the severity of an impact or create a new impact without appropriate agency

approval, and that complies with the intent of the mitigation measure.

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A proposed project change that has the potential for creating significant environmental effects will

be evaluated to determine whether supplemental CEQA review is required. Any proposed

deviation from the approved project, adopted mitigation measures, APMs, and correction of such

deviation, will be reported immediately to the CPUC Monitoring PD and PM for their review. The

CPUC Monitoring PD and PM will review the variance request to ensure that all of the

information required to process the variance is included and then forward the request to the

CPUC Project Manager for review and approval. The CPUC Project Manager may request a site

visit from the CPUC EM or need additional information to process the variance. In some cases, a

variance may also require approval by jurisdictional agencies. In general a variance request must

include the information listed below.

Detailed description of the location, including maps, photos, and/or other supporting

documents

How the variance request deviates from a project requirement

Biological resource surveys or verification that no biological resources would be

significantly impacted

Cultural resource surveys or verification that no cultural resources would be

significantly impacted.

Agency approval (if necessary)

A sample variance request form is included as Appendix D.

3.2.2 TEMPORARY EXTRA WORK SPACE PROCEDURES For the purposes of this MMCRP, Temporary Extra Work Space (TEWS) is defined as a work space

that would be utilized by PG&E during construction for a period of up to 60 days, and that was

not identified and evaluated during the CEQA process. Anything required to be utilized for a

period longer than 60 days will require a variance (see Section 3.2.1). PG&E must demonstrate

that: the TEWS is located in a disturbed area with no sensitive resources or land uses onsite or

adjacent to the proposed work space, PG&E has permission of the applicable landowner (e.g.,

municipality or private) to use the work space, and that use of the TEWS would not result in any

significant environmental impacts. In the event that PG&E determines a need for a construction

TEWS, it must submit such a request to the CPUC Monitoring PD. The CPUC Monitoring PD will

have the authority to approve or deny use of a TEWS, assuming it meets the criteria defined in the

previous paragraph. PG&E will not be permitted to use a TEWS prior to receiving written

authorization from the CPUC Monitoring PD. .

Following is a list of the specific information that PG&E would be required to submit with its

TEWS request:

Date of request;

Location of the TEWS (detailed description, including maps if required);

Property owner of TEWS;

An explanation of the necessity for the TEWS;

An analysis that demonstrates no new significant impacts would result from use of the

TEWS including: compaction contributing to runoff rates or other

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stormwater/watershed effects; observed existing impacts to the site, such as old oil spills

or other potentially hazardous or polluting substances; abandoned vehicles, equipment

or other materials; or other sensitive resources;

Biological and botanical survey, especially for invasive plants, and mitigation for

invasive plants if present.

Duration and dates of expected use of the TEWS.

Details of the expected condition of the site after use.

A sample TEWS form is included as Appendix E.

3.3 Records Management

Any daily inspection and weekly status reports will be filed and used by the CPUC third-party

monitor to prepare a brief, final environmental compliance report following the completion of

construction. The final report will provide a discussion on how each mitigation measure was

implemented and include copies of submittals required for compliance. In addition, the success

criteria will be evaluated and used for future projects.

3.4 Public Access to Records

The public is allowed access to records and reports used to track the monitoring program.

Monitoring records and reports will be made available by the CPUC for public inspection on

request.

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Chapter 4: Mitigation Monitoring Program Table

4.1 Using the Table

The table in Appendix F lists the mitigation measures included in the Final IS/MND and the CPUC

decision (10-05-006) dated May 6, 2010. The Mitigation Monitoring Program table is the core

document for environmental requirements on the project, and is the primary guideline for

determining compliance with the MMCRP. A copy of the table should be kept with each crew

working on the ROW, and all supervisory staff working on the project should be familiar with its

contents.

The CPUC will use a modified version of the mitigation measure tables during the preconstruction

planning and construction monitoring phases of the project to accurately track the status of

mitigation measures. Tables will be sorted and divided into pre-construction measures and

measures to be implemented during construction. Similarly, a separate table listing mitigation

measures that require CPUC approval may be generated. The modified tables will also include a

status column that will be updated on a regular basis.

4.2 Effectiveness Review

The CPUC may conduct a comprehensive review of conditions which are not effectively

mitigating impacts, at any time it deems appropriate, including as a result of the Dispute

Resolution procedure outlined in Section 2.3.6. If the Commission determines that any conditions

are not adequately mitigating environmental impacts caused by the project, then the Commission

may, in coordination with PG&E, develop alternative measures to effectively mitigate these

impacts. These reviews will be conducted in a manner consistent with the Commission’s rules and

practices.

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Appendix A: Project Segment Maps

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Appendix B: Project Contact List

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Project Contact List

Name Agency/

Company

Job Title/Duties Phone Number/Fax

Number

Email Address

Billie Blanchard CPUC CPUC Project Manager (415) 703-2068 (office) [email protected]

Jo Lynn Lambert PG&E Attorney (909) 793-4942 (office)

(909) 528-6436 (cell)

(415) 973-5248 (PG&E)

[email protected]

Sam Danner PG&E Land Planner (805) 305-7489 (cell)

(805) 546-3836 (office)

[email protected]

Lee Ellis PG&E PG&E Project Construction Manager (805) 260-9331 (office) [email protected]

Jeff Glenn PG&E PG&E Construction Management

Jim Layugan PG&E PG&E Construction Management

Colleen Taylor CH2M Hill Environmental Lead (510) 587-7644 (office)

(510) 316-7406 (cell)

[email protected]

Nicole McNair ETIC SWPPP Lead (925) 602-4710 x 44 (office)

(925) 408-6616 (cell)

[email protected]

TBD ETIC SWPPP Monitor

Christophe Descantes PG&E Cultural Lead (415) 973-1177 (office)

(925) 719-2740 (cell)

[email protected]

Rick Hernandez PG&E Hazardous Material Lead (805) 595 6376 (office)

(805) 441 6408 (cell)

[email protected]

TBD Garcia and

Associates

Environmental Monitors

Brent Miyazaki RMT CPUC Monitoring Project Director (323) 337-6513 (cell) [email protected]

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APPENDIX B: PROJECT CONTACT LIST

B-2 Mitigation Monitoring, Compliance, and Reporting Program

Project Contact List (Continued)

Name Agency/

Company

Job Title/Duties Phone Number/Fax

Number

Email Address

Bonny O’Connor RMT CPUC Monitoring Project Manger (650) 373-1200 (office) [email protected]

Charina Gaspay RMT CPUC Environmental Monitor (650) 373-1200 (office) [email protected]

Aaron Lui RMT CPUC Environmental Monitor (650) 373-1200 (office) [email protected]

Logan Wicks RMT CPUC Environmental Monitor (213) 458-5660 (cell) [email protected]

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Appendix C: Communication Protocol Summary

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APPENDIX C: COMMUNICATION PROTOCOL SUMMARY

Cabrillo-Santa Ynez 115 kV Reconductoring Project C-1

June 2010

Section 2.3 of the Mitigation Monitoring, Compliance and Reporting Program (MMCRP) includes

a communication protocol to ensure that CPUC Environmental Monitors (CPUC EMs) have access

to project information, including schedules, mitigation measure status, and survey results. The

communication protocol was also developed to establish a chain of command that will be used to

report environmental issues observed during CPUC EM site inspections. The following table

provides an outline of the communication protocol. For additional information, refer to Sections

2.0 and 3.0 of the MMCRP.

Table C-1: Communication Protocol

Action Item Responsibility Primary

Contact

Secondary

Contact/

Participants

Description

Meetings

Regular

Construction

Meetings

PG&E CM CPUC’s EM TBD Regular construction meetings to

be held in the field to discuss

construction progress and

construction and environmental

issues. Refer to Section 2.3.2 of

the MMCRP.

Bi-Weekly

Teleconference

Calls

CPUC

Monitoring PD

CPUC PM CPUC

Monitoring

PM

CPUC EMs

PG&E CM

PG&E PM

PG&E EMs

Bi-weekly teleconference call to

discuss status of mitigation

measures, construction schedule,

issues noted during site visits,

and project changes.

Field Meetings PG&E or

CPUC EMs

TBD TBD Field meetings may be requested

by any party to discuss variance

requests, non-compliances, or

other site-specific issues.

Project Changes

Scheduling PG&E PM CPUC

Monitoring

PM

CPUC EMs Changes in project schedule that

could affect the status of

mitigation measures will be

communicated to the CPUC

Monitoring PM by email. If the

project change would have an

immediate impact, the CPUC

EM or will be contacted by

phone.

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APPENDIX C: COMMUNICATION PROTOCOL SUMMARY

C-2 Mitigation Monitoring, Compliance, and Reporting Program

Table C-1 (Continued): Communication Protocol

Action Item Responsibility Primary

Contact

Secondary

Contact/

Participants

Description

Variance

Requests

PG&E PM or

Environmental

Lead

CPUC

Monitoring

PM

CPUC

Monitoring

PD and CPUC

PM

All variance requests will be

submitted to the CPUC

Monitoring PM through the

variance request form and

supporting documentation. The

CPUC Monitoring PM will

forward the variance request to

the CPUC PM and CPUC

Monitoring PD after verifying

the information is complete. The

CPUC PM will distribute a

variance request approval or

denial after review is complete.

Refer to Section 3.2.1 of the

MMCRP.

Compliance Issues

Minor Incidences

and Non-

compliance

CPUC EM or

CPUC

Monitoring PM

PG&E PM or

Environmental

Lead

PG&E TBD Minor incidences and non-

compliances noted during site

inspections will be documented

by the CPUC EMs and sent to

PG&E for corrective action.

Notification of a minor incident

or non-compliance will occur no

later than the following day. If

PG&E corrects the issue before

the report is issued, it will be

noted in the report. Refer to

Section 2.3.6 of the MMCRP.

General

Concerns

CPUC EMs PG&E EM PG&E (TBD) The CPUC EMs will contact

PG&E EMs to discuss general

issues and questions that come

up during site visits. The CPUC

may talk with other crew

members on the ROW, but will

not direct their work or rely on

them for information regarding

the project.

Agency

Jurisdiction

Concerns

PG&E PM Applicable

Agency

CPUC

Monitoring

PM

The resource agencies will be

notified by PG&E of any issues

regarding their jurisdiction. The

CPUC Monitoring PM will also

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APPENDIX C: COMMUNICATION PROTOCOL SUMMARY

Cabrillo-Santa Ynez 115 kV Reconductoring Project C-3

June 2010

Table C-1 (Continued): Communication Protocol

Action Item Responsibility Primary

Contact

Secondary

Contact/

Participants

Description

receive immediate notification.

Communication between PG&E

and resource agencies will be

documented and submitted to

the CPUC Monitoring PM.

In addition, if the CPUC

Monitoring PM have an

unresolved concern about

compliance with agency

requirement, they will request to

participate in a call with PG&E

and the resource agency.

Dispute

Resolution

All CPUC

Monitoring

PM or PD

CPUC PM In the event that a dispute

cannot be resolved in the field,

the CPUC Project Manager may

issue a formal letter. Refer to

Section 2.3.6 of the MMCRP.

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APPENDIX C: COMMUNICATION PROTOCOL SUMMARY

C-4 Mitigation Monitoring, Compliance, and Reporting Program

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Appendix D: Variance Request Form

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APPENDIX D: VARIANCE REQUEST FORM

Cabrillo-Santa Ynez 115 kV Reconductoring Project D-1

June 2010

Variance Request No.:

Environmental Variance Request Form

Cabrillo – Santa Ynez 115kV Reconductoring Project

Date: Date by which Approval is Required:

Location: Current Land Use:

Ownership: Private County Road: Other:

Drawing/Plan No.: Drawing/Sketch Attached? Yes No

Variance Summary Description:

Describe variance in detail:

Reason for the variance:

----------------------------------------------------------------------------------------------------------------------------------

This part to be completed by Environmental Monitor

Botanical Survey Required? Yes No

If yes, results of survey: Survey Date:

If no, explain why survey not needed:

Survey report attached? Yes No Submitted separately by (date)

Wildlife Survey Required? Yes No

If yes, results of survey: Survey Date:

If no, explain why survey not needed:

Survey report attached? Yes No Submitted separately by (date)

Cultural or Paleontology Resource Survey Required? Yes No

If yes, results of survey: Survey Date:

If no, explain why survey not needed:

Survey report attached? Yes No Submitted separately by (date)

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APPENDIX D: VARIANCE REQUEST FORM

D-2 Mitigation Monitoring, Compliance, and Reporting Program

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Appendix E: Temporary Extra Work Space Form

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APPENDIX E: TEMPORARY EXTRA WORK SPACE FORM

Cabrillo-Santa Ynez 115 kV Reconductoring Project E-1

June 2010

Date: Requested Date of Approval: Prepared by:

Location/Address:

Proposed Use of Site:

Proposed Date(s) of Use Proposed Hours of Use:

Note: Proposed Dates of Use must be less than 60 days or a Variance Request will be required.

Adjacent Land Uses:

Biological, Cultural and Paleontological reconnaissance surveys are mandatory for use of any

areas containing vegetation, or exposed earth that have not been previously surveyed and fully

described in project documents. Biological surveys are mandatory for all temporary extra work

sites. Attach a diagram of the proposed area that identifies the location of the site and proximity to

sensitive resources or receptors.

Complete the Environmental Checklist below.

Note: Yes answers require additional clarification and should be submitted as an attachment to this form.

Environmental Checklist Yes No CPUC Verified

Air Quality: Would equipment be on site or idled for more than 10

minutes? Would there be dust-producing activities?

Biological Resources: Would use of the site result in potential impacts to

sensitive biological resources? Would use of the site result in potential

for the spread of noxious weeds?

Cultural/Paleontological Resources: Would clearing or grading be

required?

Water Resources: Would runoff from the site flow into storm drains or a

waterway? Would equipment refueling or maintenance be performed?

Would materials block/impact storm drains or gutters?

Land Use and Recreation: Would use of site block access to local land

uses and recreational areas?

Noise: Are noise-sensitive receptors (e.g., homes, schools, hospitals,

churches convalescent homes, parks, recreational areas) adjacent to the

site?

Socioeconomics: Would access to business be blocked? Would there be

disruption of business operations?

Traffic: Would parking be eliminated? Would increased construction

traffic result in impacts? Is the site a residential area?

Visual: Would lights at site create glare for adjacent land uses (including

roadways)?

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APPENDIX E: TEMPORARY EXTRA WORK SPACE FORM

E-2 Mitigation Monitoring, Compliance, and Reporting Program

Standard Conditions of Approval

The CPUC, via its designated Environmental Monitor, will review and approve/deny

the Temporary Extra Workspace Request (TEWS) request within four business days of

receiving this completed form.

Use of TEWS is limited to 60 days. First proposed date of use:

Use of TEWS shall be in compliance with local ordinances (including traffic/noise) and

mitigation measures.

If any signs of cultural resources are identified, work shall cease immediately and the

site shall be reevaluated.

The proposed site shall not be used for storage of fuel or hazardous materials.

All drips, leaks, and/or spills from vehicles and/or equipment shall be cleaned-up

immediately and disposed of in appropriate, labeled containers.

Adjacent streets shall be swept or cleaned with water at the end of each workday if

visible soil material is carried on them.

No parking or storage of vehicles (including personnel vehicles), equipment, pipe, or

any other project- related item shall be allowed on adjacent roadways.

If a complaint is received, it shall be forwarded to the PG&E Permit Coordinator, the

CPUC EM, and the CPUC Monitoring PD for review.

The following signatures indicate that the proposed site is approved for TEWS. On a random

basis, a CPUC EM will verify that use of the proposed site is in accordance with the conditions

noted. This approval may be revoked at any time by any one of the approval team. Failure to

comply with all conditions will result in immediate revocation of this TEWS approval.

Property Owner: Date:

PG&E Construction: Date:

PG&E Permit Coordinator: Date:

The above TEWS request and attached documentation have been reviewed and this request is

approved or denied (circle one).

CPUC Monitoring Project Director: Date:

Additional CPUC Conditions of Approval

(CPUC Monitor Initial ______)

Reason(s) for Denial

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Appendix F: Mitigation Monitoring Program Table

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-1

June 2010

Mitigation Monitoring Program Table

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

APM AE-1 APM Aesthetics (AE)-1: New source of substantial light or glare avoidance. PG&E will

replace the existing conductor with a non-specular conductor for the specific purpose of

minimizing the reflectivity of any new project facilities.

Verify equipment

through on-site

monitoring or photo

documentation.

During construction

APM LU-1 APM Land Use (LU)-1: Agriculture impacts avoidance. To avoid potential impacts to

agriculture, PG&E will work with farmers and ranchers to conduct its work between their

harvest and planting periods where and whenever possible. In areas containing permanent

crops (i.e., grape vines, tree orchard, etc.) that must be removed and replaced to gain

access to poles sites for construction purposes, PG&E will provide compensation to

landowners for crop loss and other reasonable and associated costs as soon as practicable

after completion of construction. Access across active crop areas will be negotiated with

the owners in advance of any construction activities

Verify coordination

with landowners

through

documentation

During construction

APM AQ-1 Mitigation Measure AQ-1 (Proposed to supersede APM AQ-1): The following fugitive

dust control measures would be implemented unless otherwise approved by the

SBCAPCD. Copies of the finalized dust control measures would be submitted to the CPUC

for recordkeeping.

PG&E would use water trucks or sprinkler systems during

construction on all active construction and disturbed areas to keep

areas of vehicle and equipment movement sufficiently damp to

prevent dust from leaving the site. At a minimum, this would include

wetting down these areas in the late morning and after work is

completed for the day. Watering frequency would increase whenever

the wind speed exceeds 15 miles per hour (mph).

Reclaimed water will be used whenever possible; however, reclaimed

water will not be used in or around crops for human consumption.

Confirm the CPUC

has received the

name and telephone

number(s) of the

designated

monitor(s) for the

Dust Control

Program

Prior to construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-2 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

Construction equipment and related vehicles, including personal

vehicles, would be limited to a maximum speed of 15 mph on

unpaved roads

All exposed soil stockpiles (e.g., soil and sand) would be covered.

Gravel pads, bamboo mats, or a suitable equivalent would be installed

at all access points to prevent tracking mud on to public roads, as

discussed in the project’s Stormwater Pollution Prevention Plan

(SWPPP)

PG&E would designate a person or persons to monitor the dust

control program and to order increased watering, as necessary, to

prevent dust transport off site. Monitor duties would include holiday

and weekend periods when work may be in progress. The name and

telephone number of the monitor would be provided to the SBCAPCD

prior to project construction

Verify

implementation of

measures through

on-site monitoring

and During

construction

documentation from

Dust Control

Program designated

monitor.

Verify obtainment of

finalized dust control

measures through

documentation.

During construction

APM GHG-1 APM Greenhouse gas (GHG)-1: GHG emissions minimization. The following measures

will be implemented during construction to minimize GHG emissions.

Park-and-ride facilities in the Project vicinity will be identified and construction workers

will be encouraged to carpool to the job staging area to the extent feasible. The ability to

develop an effective carpool program for the Proposed Project will depend upon the

proximity of carpool facilities to the staging area, the geographical commute departure

points of construction workers, and the extent to which carpooling will not adversely affect

worker arrival time and the Project’s construction schedule. Crew transportation to the

Project site is discussed in Section 4.10, Traffic and Transportation.

Unnecessary construction vehicle idling time will be minimized. The ability to limit

construction vehicle idling time is dependent upon the sequence of construction activities

and when and where vehicles are needed or staged. Certain vehicles, such as large diesel

Verify

implementation of

measures through

on-site monitoring

and documentation

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-3

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

powered vehicles, have extended warm-up times following start-up that limit their

availability for use following startup. Where such diesel powered vehicles are required for

repetitive construction tasks, these vehicles may require more idling time. The Proposed

Project will apply a “common sense” approach to vehicle use; if a vehicle is not required

for use immediately or continuously for construction activities, its engine will be shut off.

Construction foremen will include briefings to crews on vehicle use as part of pre-

construction conferences. Those briefings will include discussion of a “common sense”

approach to vehicle use.

Construction equipment will be maintained in good working order, per manufacturing

specifications. Low-emission construction equipment will be used where feasible to further

minimize the minimal short-term increase in GHG emissions. With implementation of

APM GHG-1, the entire construction effort for this project is forecasted to create 379 metric

tons of CO2 which represents a small fraction of the emissions limit set by AB322020 (427

million metric tons CO2e).

APM BO-1 APM Biological Resources (BO)-1: General avoidance of biological resources impacts.

Litter and trash management. All food scraps, wrappers, food containers, cans, bottles, and

other trash from the Project area will be deposited in closed trash containers. Trash

containers will be removed from the Project area at the end of each working day.

Verify

implementation of

measures through

on-site monitoring

and documentation

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-4 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

Parking. Vehicles and equipment will be parked on pavement, existing roads, and

previously disturbed or developed areas or work areas as identified in this document. Off-

road parking shall only be permitted in previously identified and designated work areas.

Route and speed limitations. Vehicles will be confined to established roadways and pre-

approved access roads, overland routes and access areas. Access routes and temporary

work areas will be limited to the minimum necessary to achieve the Project goals. Routes

and boundaries of work areas, including access roads, will be clearly mapped prior to

initiating Project construction. Vehicular speeds will be kept to 15 mph on unpaved roads.

Maintenance and refueling. All equipment will be maintained such that there will be no leaks

of automotive fluids such as fuels, solvents, or oils. All refueling and maintenance of

vehicles and other construction equipment will be restricted to designated staging areas

located at least 100 feet from any down gradient aquatic habitat unless otherwise isolated

from habitat. Proper spill prevention and cleanup equipment shall be maintained in all

refueling areas.

Minimization of fire hazard. During fire season in designated State Responsibility Areas, all

motorized equipment driving off paved or maintained gravel/dirt roads will have federal

or state approved spark arrestors. All off-road vehicles will be equipped with a backpack

pump filled with water and a shovel. All fuel trucks will carry a large fire extinguisher

with a minimum rating of 40 B:C, and all equipment parking and storage areas will be

cleared of all flammable materials.

Pets and firearms. No pets or firearms will be permitted at the Project site.

Verify

implementation of

measures through

on-site monitoring

and documentation.

During operation

APM BO-2 APM BO-2: Avoidance of impacts to natural habitats

Minimization of grading and vegetation removal along access roads and pole work areas.

Clearing and grading will be limited to previous access roads that have become overgrown

with vegetation. Overland access routes and work areas around pole locations will not

require any grading or vegetation removal other than minimal tree trimming as described

Verify

implementation of

measures through

on-site monitoring

and documentation

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-5

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

in the Project description.

Tree removal. A single tree, a Leland Cypress, is planned for removal as described in the

Project description. No other tree removal is planned.

Re-vegetation. Since clearing and grading is limited to re-establishment of existing roads,

no re-vegetation is needed for the Project. Temporarily disturbed vegetation is expected to

recover without the need for reseeding.

APM BO-4 APM BO-4: General avoidance and minimization of impacts to aquatic or wetland

habitat.

Timing and extent of work in aquatic or wetland habitat. Work in aquatic or wetland

habitat is limited to the removal of two poles and replacement of one pole in the wetland

northeast of SR 246. All ground-disturbing work at this location will take place in dry

conditions. The timing is dependent on seasonal rainfall; in winter 2008-2009, ground was

dry even in January.

Verify construction

activities through on-

site monitoring and

documentation

During construction

in wetland or

aquatic habitat

APM BO-5 APM BO-5: Avoidance of impacts to California red-legged frog, California tiger

salamander, western spade foot toad and western pond turtle in proximity to identified

suitable breeding ponds or aquatic habitat.

Dawn and dusk timing restrictions. Construction activities within 600 feet of suitable

aquatic habitat shall not begin prior to 30 minutes after sunrise and will cease no later than

30 minutes before sunset.

Erosion control materials. Only tightly woven netting or similar material shall be used for

all geo-synthetic erosion control materials such as coir rolls and geo-textiles. No plastic

monofilament matting will be used.

Confirm construction

time requirements for

aquatic habitat.

Ensure netting

material is made of

suitable material

Prior to construction

Confirm construction

time requirements for

aquatic habitat.

Ensure netting

material is made of

suitable material

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-6 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

APM BO-9 Avoidance of and minimization of potential impacts to wetlands and water resources.

Stormwater Pollution Prevention Plan and erosion control measures. As described in

Section 4.8, APMs WQ-1 and WQ-3, a Stormwater Pollution Prevention Plan (SWPPP) will

be developed that describes sediment and hazardous materials control, fueling and

equipment management practices, and other factors deemed necessary for the Project.

Erosion control measures will be implemented where necessary to reduce erosion and

sedimentation in wetlands, waters of the United States, and waters of the state, as well as

aquatic habitat occupied by sensitive species. Erosion control measures will be monitored

on a regularly scheduled basis, particularly during times of heavy rainfall. Corrective

measures will be implemented in the event erosion control strategies are inadequate.

Sediment/erosion control measures will be continued at the Project site until such time that

soil stabilization is deemed adequate. Brush or other similar debris material will not be

placed within any stream channel or on its banks. No Project work activity is planned

within the limits of any stream channel.

Verify required

contents in the

SWPPP

Prior to construction

Verify SWPPP and

erosion control

measure are being

implemented

correctly through on-

site monitoring and

documentation.

Verify that

supplementary

measures are being

implemented as

necessary through

on-site monitoring.

During construction

MM Bio-1 Mitigation Measure Bio-1 (Proposed to supersede APM BO-1 “Development and

implementation of a Worker Environmental Awareness Program”): A qualified biologist

would conduct an environmental awareness program for all construction and on-site

Verify required

contents in the

WEAP.

Prior to construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-7

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

personnel prior to the beginning of construction activities. Training would include the

following topics and information:

A discussion of avoidance and minimization measures being implemented to protect

biological resources as well as the terms and conditions of the Biological Opinion and other

permits.

A map depicting all of the locations of previously flagged/marked sensitive and special

status plants. The map would be accompanied with an explanation of how the locations

were demarcated out in the field.

Information on the federal and state Endangered Species Acts, as well as other applicable

state and federal laws protecting sensitive plant and wildlife species, nesting birds,

wetlands, and other water resources. The consequences of noncompliance with these acts

and laws would be disclosed to the workers.

Information about the presence, life history, defining characteristic, and habitat

requirements of all special-status species with a potential to be affected within the project

area.

An educational brochure would be produced for construction crews working on the

project. The brochure would include color photos of sensitive species as well as a

discussion of mitigation measures.

Verify all

construction and on-

site personnel have

undergoing training

through

documentation and

on-site monitoring.

During Construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-8 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

MM Bio-2 Mitigation Measure Bio-2 (Proposed to supersede APM BO-1 “Biological monitor on-

site during construction activities in sensitive areas” and “Reporting and

communication”): A qualified biological monitor would be on site during all ground-

disturbing construction activities in or near sensitive habitats previously identified by a

qualified biologist. The monitor would ensure implementation of and compliance with all

avoidance and mitigation measures. The monitor would have the authority to stop work or

determine alternative work practices in consultation with agencies and construction

personnel as appropriate if construction activities are likely to impact sensitive biological

resources. The biological monitor would document monitoring activities in daily logs to

document construction activities and environmental compliance. The daily logs would be

included in the project report submitted to the appropriate agencies following completion

of construction.

The biological monitor would be responsible for reporting any capture and relocation,

harm, entrapment, or death of a listed species to the USFWS and/or the CDFG and for

reporting any permit violations in a timely manner and as indicated in their respective

permits. Weekly monitoring reports would be submitted to CPUC, and to any resource

agencies (upon request), throughout construction. A final project summary report would

be submitted to the CPUC 90 days after the completion of construction activities.

Confirm

qualifications of the

monitor

Prior to construction

Verify biological

monitoring through

daily logs and

reports.

During construction

MM Bio-3 Mitigation Measure Bio-3 (Proposed to supersede APM BO-1 “Identification and

marking of sensitive resource areas”): Sensitive resources identified during pre-

construction surveys in the project vicinity would be mapped and clearly marked in the

field. Such areas would be avoided during construction to the extent practicable and/or

additional measures specific to sensitive species types as described herein and that may be

required by the USACE, FWS, CDFG, and RWQCB permits, would be implemented to

avoid or minimize impacts.

Verify that sensitive

areas are clearly

marked and avoided

through on-site

monitoring.

During construction

MM Bio-4 Mitigation Measure Bio-4 (Proposed to supersede APM BO-2 “Weed management”):

All project vehicles would be washed before arrival on site at PG&E’s Santa Maria,

Verify vehicles are

washed thoroughly

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-9

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

Lompoc, or Buellton PG&E wash facilities or otherwise approved wash-down location.

Vehicles would also be cleaned at an appropriate wash facility, at the completion of the

project or when off-road use for that vehicle has been completed.

prior to arriving on-

site and at the

completion of use on-

site through on-site

monitoring.

MM Bio-5 Mitigation Measure Bio-5 (Proposed to supersede APM BO-3 “Avoidance of and

minimization of potential impacts to special-status plants”): A pre-construction survey

would be conducted by a qualified botanist or biologist prior to commencement of

construction in each area. All rare plant populations would be appropriately marked or

flagged for exclusion, or as appropriate, the limits of construction will be marked between

the population and the work area. Surveys and marking or flagging must be completed no

more than 30 days prior to construction. In the event that any previously unidentified

listed plants, or CNPS List 1-3 plants cannot be avoided, PG&E would consult with the

USFWS and/or the CDFG (depending on whether the species is on the federal or state list

of sensitive species) to determine appropriate measures to minimize effects to the species

and its habitat during construction of the project, as well as during operation and

maintenance. The CPUC would be informed of the results of any agency consultations.

Verify the completion

of survey through

documentation.

Verify necessary

marking or flagging

through photo

documentation or on-

site visit.

Verify any necessary

agency consultations

through

documentation.

No more than 30

days prior to

construction

Verify that sensitive

plants are clearly

marked and avoided

through on-site

monitoring.

Verify agency

consultations, if

necessary, through

documentation.

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-10 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

MM Bio-6 Mitigation Measure Bio-6 (Proposed to supersede APM BO-5 “Pre-construction surveys

and relocation of species”): Pre-construction surveys for special-status amphibians and

aquatic reptiles would be conducted no more than two weeks prior to the commencement

of construction. Surveys would include work areas within 600 feet of suitable CTS

breeding habitat and work areas within 300 feet of suitable CRLF aquatic habitat. Surveys

would be conducted by a qualified, agency-approved biologist. Potential habitat for

western spade foot toad and western pond turtle exists in similar locations to those for

CRLF and CTS. The biologist would relocate any special-status species to a location

previously agreed upon by the USFWS and the CDFG. Before the start of work each

morning, the biologist would check under any equipment and stored construction supplies

left in the work area overnight within 600 feet of suitable habitat. All pole holes would be

backfilled or covered at the end of the work day to prevent entrapment of special-status

species.

Verify the completion

of survey through

documentation.

No more than 2

weeks prior to

construction in

suitable habitat

buffer.

Verify daily

biological sweep of

work area within

suitable habitat

through

documentation and

on-site monitoring.

During construction

MM Bio-7 Mitigation Measure Bio-7 (Proposed to supersede APM BO-5 “Seasonal timing

restrictions”): All ground-disturbing construction activities within 600 feet of suitable

habitat for CFLF, CTS, western spade foot frog, and western pond turtle would be limited

to May 1 through October 31, to the greatest extent feasible. For work in these areas, a

qualified biologist would conduct a pre-construction survey of the work area immediately

preceding construction activities. All potential habitat areas including burrows, woody

debris piles, wetlands, riparian areas, and edges of ponds within the work area would be

thoroughly checked. Any special-status species found would be captured and relocated to

a FWS and CDFG approved location type (e.g., a small mammal burrow) and area, prior to

the start of construction.

Verify the completion

of survey through

documentation.

Immediately prior to

construction in

suitable habitat

buffer.

Verify construction

activities to only

occur during May1 to

October 31within

suitable habitat

through on-site

monitoring and

documentation.

During construction

MM Bio-8 Mitigation Measure Bio-8 (Proposed to supersede APM BO-5 “Minimization of burrow

disturbance”): Plywood sheets would be used to temporarily cover potentially active

Verify plywood

sheets are used to

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-11

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

burrows in work areas within 600 feet of suitable breeding habitat. Burrows would be

covered after re-location has taken place, if necessary, or otherwise specified in the

Biological Opinion.

cover potentially

active burrows after

relocation or in

accordance to BO

protocol through

documentation and

on-site monitoring.

MM Bio-9 Mitigation Measure Bio-9 (Proposed to supersede APM BO-6 “Avoidance of and

minimization of potential impacts to southwestern willow flycatcher and least Bell’s

vireo”): Work anticipated within 300 feet of the potential nesting habitat for these species

and the designated critical habitat for southwestern willow flycatcher includes the use of

pull site P1 and insulator replacement at Poles 4, 5, and 6. Insulator replacement and use of

the pull site would be restricted to the non-nesting season. For the purposes of this

measure, the nesting season for these species is considered to be March 15 to September 15.

Additionally, the raptor nesting season extends from February 1 through August 15. Work

within the period of February 1 to September 15 in this area would only occur if pre-

construction surveys determine these species are not actively nesting within 300 feet of the

work areas, or a qualified biologist is present during all activities to monitor for potential

nest disturbance per an Avian Protection Plan as described in Mitigation Measure Bio-12.

Verify the completion

of survey through

documentation.

Prior to construction

Verify construction

activities to only

occur during

September 16 to

January 31 to within

critical habitat

through on-site

monitoring and

documentation.

Verify results of

preconstruction

surveys through

documentation to

allow work to occur

from January 31

through March 14.

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-12 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

MM Bio-10 Mitigation Measure Bio-10 (Proposed to supersede APM BO-7 “Avoidance of and

minimization of potential impacts to western burrowing owl”): The following methods

would be employed unless otherwise approved by CDFG or USFWS. Pre-construction

burrowing owl surveys would be conducted by a qualified biologist within 250 feet of

areas within burrowing owl habitat subject to disturbance. Burrowing owl surveys would

follow the CDFG’s Burrowing Owl Protocol Survey and Mitigation Guidelines (California

Burrowing Owl Consortium 1993) and shall occur between February 1 and September 30.

If ground-disturbing activities are delayed or suspended for more than 30 days after the

pre-construction surveys, the site would be resurveyed. If no burrowing owls are

detected, no further mitigation is necessary.

Appropriate avoidance, minimization, or protection measures shall be determined in

consultation with CDFG in the event that construction is located within 150 feet of

occupied burrows or nests during the non-breeding season, or within 250 ft of an area

Verify the completion

of survey through

documentation.

Verify PG&E’s

consultation for

appropriate

mitigation with

CDFG if burrowing

owls are detected.

30 days prior to

construction in

suitable habitat

buffer.

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-13

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

subject to disturbance during the breeding season. Measures could include, but would not

be limited to the following:

No disturbance would occur within approximately 160 feet (50 meters) of occupied

burrows during the non-breeding season of September 1 through January 31, or within

approximately 250 feet (75 meters) during the breeding season of February 1 through

August 31

The limits of the exclusion zone in the project work area would be clearly marked with

signs, flagging and/or fencing

If work within these limits is unavoidable while burrows are active, work would only take

place within the presence of a qualified monitor who would monitor to determine if the

owls show signs of disturbance or, upon prior approval from CDFG a passive relocation

effort (displacing the owls from the work area) may be conducted as described below, and

subject to the approval of the CDFG.

Passive relocation of owls may occur during the non-breeding season (September 1

through January 31) with prior approval from CDFG. Passive relocation would include

installing one-way doors on the entrances of burrows. The one-way doors would be left in

place for 48 hours to ensure the owls have vacated the nest site. Owls would not be

relocated during the breeding season.

Verify appropriate

buffers and/or on-site

monitors are

established.

During construction

surrounding an

active burrow or

nest

MM Bio-11 Mitigation Measure Bio-11: The open ends of light-duty steel poles would be covered

during storage to prevent burrowing owls or any other sensitive species from inhabiting

the pole openings.

Verify pole ends are

covered through on-

site monitoring.

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-14 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

MM Bio-12 Mitigation Measure Bio-12 (Proposed to supersede APM BO-8 “Avoidance of and

minimization of potential impacts to song birds, raptors and other migratory bird

species”): Pre-construction bird nesting surveys for pull sites or locations of pole

replacement or clearing and grading activities would be conducted before work performed

between February 1 and August 15. See mitigation measure Bio-9 for pre-construction

survey requirements near the Santa Ynez River. Pre-construction surveys would be

conducted within the ROW and from the ROW of areas visible from the ROW. To the

extent possible, working in the vicinity of active nests would be avoided; however, if

avoidance is not practicable, a buffer zone, as determined by a qualified biologist, would

be maintained around the active nest to prevent nest abandonment. In the event that work

would take place within 50 feet (300 feet for raptors) of an active nest, a biological monitor

would monitor the activity of the nesting birds during work to determine if construction

activities are resulting in significant disturbance to the birds. If the qualified biologist

determines that work is disrupting nesting, then work in that area would be halted until

nesting is completed and the young have fledged. Monitoring guidelines would be

provided in an Avian Protection Plan to be submitted to the USFWS and CDFG for review

and approval prior to construction. Documentation of Plan approval would be submitted

to the CPUC for recordkeeping.

Installation of the replacement power lines would conform to PG&E’s most current version

of Bird and Wildlife Protection Standards, and would include the use of bird guards.

Verify the completion

of survey through

documentation.

Verify CDFG and

USFWS approval of

Avian Protection

Plan through

documentation.

Prior to construction

Verify appropriate

buffers and/or on-site

monitors are

established. Verify

power line

conformance with

Bird and Wildlife

Protection Standards

through

documentation.

During construction

surrounding an

active nest.

APM CR-1 APM Cultural Resources (CR)-1: Archaeological site avoidance. To ensure that Æ-1857-

3H is not inadvertently damaged during implementation of the Project, the limits of the

work areas listed in Potential Impact CR-1 will be marked with readily visible flagging

tape and the construction crews will be instructed that there will be no vehicle access,

travel, equipment staging and storage, or other construction-related work outside of the

flagged work areas when working at Pole 13.

Verify that the

cultural site is clearly

marked and avoided

through on-site

monitoring.

During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-15

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

APM CR-2 APM CR-2: Pre-construction Worker Education Program. PG&E will design and

implement a Worker Education Program that will be provided to all Project personnel who

may encounter and/or alter historical resources or unique archaeological properties,

including construction supervisors and field personnel. No construction worker will be

involved in field operations without having participated in the Worker Education

Program. The Worker Education Program shall include, at a minimum:

A review of archaeology, history, prehistory and Native American cultures

associated with historical resources in the Project vicinity.

A review of applicable local, state and federal ordinances, laws and regulations

pertaining to historic preservation.

A discussion of site avoidance requirements and procedures to be followed in the

event that unanticipated cultural resources are discovered during

implementation of the Project.

A discussion of disciplinary and other actions that could be taken against persons

violating historic preservation laws and PG&E policies.

A statement by the construction company or applicable employer agreeing to

abide by the Worker Education Program, PG&E policies and other applicable

laws and regulations.

The Worker Education Program may be conducted in concert with other environmental or

safety awareness and education programs for the Project, provided that the program

elements pertaining to cultural resources are provided by a qualified instructor meeting

applicable professional qualifications standards.

Verify required

content in the WEP.

Prior to construction

APM CR-3 APM CR-3: Unanticipated discoveries management. In the unlikely event that previously

unidentified cultural resources are uncovered during implementation of the Project, all

work within 165 feet (50 meters) of the discovery will be halted and redirected to another

location. PG&E’s cultural resources specialist or his/her designated representative will

Verify the

implementation of

proper procedures

through

During a discovery

of a previously

unidentified cultural

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-16 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

inspect the discovery and determine whether further investigation is required. If the

discovery can be avoided and no further impacts will occur, the resource will be

documented on State of California Department of Parks and Recreation cultural resource

records and no further effort will be required. If the resource cannot be avoided and may

be subject to further impact, PG&E will evaluate the significance and CRHR eligibility of

the resources, and implement data recovery excavation or other appropriate treatment

measures if warranted.

documentation and

on-site monitoring

resource

MM Cultural-1 Mitigation Measure Cultural-1: Environmental training would be provided to workers

regarding the protection of paleontological resources and procedures to be implemented in

the event fossil remains are encountered by ground-disturbing activities. This training may

be combined with other environmental training for the project, provided that the program

elements pertaining to cultural resources are provided by a qualified instructor meeting

applicable professional qualification standards.

In the unlikely event that previously unidentified paleontological resources are uncovered

during implementation of the project, all ground disturbing work would be temporarily

halted or diverted away from the discovery to another location. PG&E’s paleontological

resources specialist or his/her designated representative would inspect the discovery and

determine whether further investigation is required. If the discovery is significant, but can

be avoided and no further impacts would occur, the resource would be documented in the

appropriate paleontological resource records and no further effort would be required. If

the resource is significant, but cannot be avoided and may be subject to further impact,

PG&E would evaluate the significance of the resources, and implement data recovery

excavation or other appropriate treatment measures as recommended by a qualified

paleontologist.

Verify required

content in the

environmental

training

documentation.

Prior to construction

Verify training of

paleontological

resources and

procedures

documentation.

Verify the

implementation of

procedures through

documentation and

on-site monitoring.

During construction

and during a

discovery of a

previously

unidentified

paleontological

resource

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-17

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

APM GM-2 APM GM-2: Soft or loose soils during construction minimization. Where soft or loose

soils are encountered during construction, appropriate measures will be implemented to

avoid, accommodate, replace, or improve soft or loose soils encountered during

construction. Such measures may include:

Locating construction facilities and operations away from areas of soft

and loose soil.

Over-excavating soft or loose soils and replacing them with

engineered backfill materials.

Increasing the density and strength of soft or loose soils through

mechanical vibration and/or compaction.

Treating soft or loose soils in place with binding or cementing agents.

Construction activities in areas where soft or loose soils are

encountered will be scheduled for the dry season to allow safe and

reliable equipment access.

Verify appropriate

measures have taken

place through on-site

monitoring

During construction

at location with soft

or loose soils

APM

HM-2/WQ-2

APM HM-2/WQ-2: Environmental Training and Monitoring Program (ETMP)

development and implementation. An environmental training program will be

established to communicate to all field personnel any environmental concerns and

appropriate work practices, including spill prevention and response measures and Best

Management Practices (BMPs). The training program will emphasize site-specific physical

conditions to improve hazard prevention (e.g., identification of flow paths to nearest

waterbodies) and will include a review of all site-specific plans, including but not limited

to the Project’s SWPPP, Erosion Control and Sediment Transport Plan, Health and Safety

Plan, and Hazardous Substances Control and Emergency Response Plan.

A monitoring program will also be implemented to ensure that the plans are followed

throughout the construction period. BMPs, as identified in the Project SWPPP and Erosion

Control and Sediment Transport Plan, will also be implemented during the Project to

Verify required

content in the WEP.

Prior to construction

Verify training and

implementation of

ETMP through

documentation and

on-site monitoring.

During construction

Verify

implementation of

ETMP through

documentation and

During operation

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-18 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

on-site monitoring.

MM Haz-1 Mitigation Measure Haz-1 (Proposed to supersede APM HM-1): PG&E would submit a

Hazardous Substance Control and Emergency Response Plan to the CPUC for

recordkeeping at least 30 days prior to project construction. The plan would identify

methods and techniques to minimize the exposure of the public to potentially hazardous

materials during all phases of project construction through operation. The plan would

require implementing appropriate control methods and approved containment and spill-

control practices (i.e., spill control plan) for construction and materials stored on-site.

All hazardous materials and hazardous wastes would be handled, stored, and disposed of,

in accordance with all applicable regulations, by personnel qualified to handle hazardous

materials. With the exception of the poles, all hazardous materials would be collected in

project-specific containers at the site, and transported to a PG&E service center designated

as a PG&E consolidation site. Poles would be scheduled for transportation to the

appropriate licensed Class 1 or a composite-lined portion of a solid waste landfill. The plan

Verify required

content in the

Hazardous Substance

Control and

Emergency Response

Plan.

30 days prior to

construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-19

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

would include, but not be limited to, the following:

Proper disposal of potentially contaminated soils

Vehicles and equipment parking near sensitive resource areas during construction

Emergency response and reporting procedures to address hazardous material

spills

Stopping work and contacting the County Fire Department, Hazardous Materials

Unit (HMU) immediately if visual contamination or chemical odors are detected.

The resumption of work would require the approval of the HMU. Work would be

resumed at this location after any necessary consultation and approval by the

HMU.1

Notifying the appropriate Certified Unified Program Agency (CUPA) inspector of

the storage and disposal locations for wooden poles removed, prior to initiating

construction

Verify

implementation of

Hazardous Substance

Control and

Emergency Response

Plan through

documentation and

on-site monitoring.

During construction

with exposure to

hazardous materials

Hazardous

Substance

Control and

Emergency

Response Plan

ON-SITE REFUELING

If on-site refueling is needed, no vehicles or equipment will be refueled within 100 feet of a

stream with a defined stream channel or bank, a wetland, or a pond unless a bermed and

lined refueling area is constructed, secondary containment is otherwise in place, or the

refueling area is down gradient or hydrologically separated (e.g. such as a site across a

road and down gradient of the wetland).

Verify refueling is

occurring in

appropriate locations

through on-site

monitoring

During refueling

events

HAZARDOUS DISPOSAL

With the exception of the poles, all hazardous materials would be collected in project-

specific containers at the site, and transported to a PG&E service center designated as a

Verify disposal is

occurring

appropriately

During construction

11 The CPUC and PG&E agreed on June 22, 2010 to change the last sentence of the second to last bullet of Mitigation Measure Haz-1 in order to clarify the process to resume work.

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

F-20 Mitigation Monitoring, Compliance, and Reporting Program

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

PG&E consolidation site. Poles removed from the Project would be scheduled for

transportation to the appropriate licensed Class 1 or a composite-lined portion of a solid

waste landfill.

If potentially contaminated soils are discovered (e.g. based on odor, color, sheen), then

work at the site would be halted, the soil would be collected and contained while awaiting

test results (i.e. in a drum). The soil will be sampled, analyzed, and characterized to

determine proper disposal.

through on-site

monitoring.

HAZARDOUS SUBSTANCE RELEASE RESPONSE PLAN

The Hazardous Substance Release Response Plan is to be followed as a control measure in

the event of a hazardous substance release. Steps included,

Initial response

Containment techniques

Emergency coordinator duties

Emergency response plan

Clean up of insulating oil

Sampling requirements

Transportation and handling of release clean up debris hazardous waste

Notifications

Document retention

Verify Hazardous

Substance Release

Response Plan

through

documentation.

During hazardous

spills

MM Haz-2 Mitigation Measure Haz-2 (Proposed to supplement APM HM-2/WQ-2): PG&E would

prepare a site-specific Health and Safety Plan (HSP) to ensure that potential safety hazards

would be kept at a minimum. The HSP would include elements that establish worker

training and emergency response procedures relevant to project activities. The plan would

Verify required

content in the Health

and Safety Plan

30 days prior to

construction

Verify training and During construction

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APPENDIX F: MITIGATION MONITORING PROGRAM TABLE

Cabrillo-Santa Ynez 115 kV Reconductoring Project F-21

June 2010

Mitigation Monitoring Program Table (Continued)

APM/

Mitigation

Measure

APM/Mitigation Measure Implementation/

Monitoring Method

Implementation

Schedule

be submitted to the CPUC at least 30 days prior to construction for CPUC recordkeeping. implementation of

HSP through

documentation and

on-site monitoring.

Verify

implementation of

HSP through

documentation and

on-site monitoring.

During operation

Health and

Safety Plan

All personnel working on this project or in the area of this project will read and be familiar

with this HASP before doing any work. All project personnel will sign the certification

page acknowledging that they have read and understand this HASP.

Verify training logs

to ensure that all

project personnel

have signed the

certification page

through

documentation.

During construction

WORKER BOUNDARIES – ENERGIZED LINES

When work will occur near energized electrical lines, clearly defined work boundaries and

limits will be established (e.g. applicable regulations, including NFPA 70E). A 25-foot set-

back distance from live electrical lines is the communicated safe working distance for

mobile equipment.

Physical barriers will be constructed, if necessary, to limit equipment proximity and warn

operators of this hazard. Qualified, high voltage electrical workers may work closer than

25 ft to energized conductors.

Verify distance of

workers from

energized electrical

lines through on-site

monitoring.

During construction

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FLAME RETARDANT CLOTHING

Every person will ensure that they wear Flame Retardant (FR) clothing that has an arc

rating greater than or equal to the available hear energy whenever they are within the Arc

Flash Boundary. In addition, everyone will ensure that they wear clothing that cannot melt

or ignite and continue to burn in the presence of electric arcs to which personnel could be

exposed, whenever they are working on or around PG&E electrical facilities. All garments

will have tags visible from the outside that clearly identified the garment as Flame

Resistant and clearly indicates the arc rating (HRC category) of the garment. All garments

will have a minimum rating of HRC 2. PG&E personnel will refer to the PG&E Flame-

Resistant (FR) Clothing Procedures (Utility Work Procedure WP2509) to determine the

appropriate Flame Retardant clothing for this Project.

Verify flame

resistance of worker’s

clothing within 12 ft

of the 115kV line

through on-site

monitoring.

During construction

SAFETY VESTS

When deciding which vest (Class III or Class II) to wear, employees will comply with the

following regulations:

Class III vests are required in traffic areas where vehicle speeds exceed 50 mph; high

volume traffic and unmonitored equipment movement; users and vehicle operators with

multi-task loads that divert attention and increase risk; complex backgrounds; work

activities taking place in or near unimpeded vehicle traffic; work activities taking place

under icy or snowy conditions; and work activities taking place in low light or at

nighttime.

A traffic area is defined as any roadway, highway, freeway, street or parking lot area, as

well as construction sites and PG&E yards where employees on foot are exposed to

moving construction vehicles or equipment.

Additionally, the Class III vests are Flame Retardant, can be worn in Arc Flash Hazard

boundaries. In addition to the new safety vests, the long-sleeve orange FR shirt with

reflective material also meets the Class III standard and the ANSI visibility standard.

Verify proper vest are

being worn by

construction

personnel through

on-site monitoring.

During construction

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Employees wearing these shirts are not required to wear a safety vest over them.

Class II vests are required in all other situations (day or night at speeds under 50 mph).

Class II vests are Flame Retardant, can be worn in Arc Flash Hazard boundaries.

TAIL GATE MEETINGS

Tailgate safety briefings will be conducted, as needed, at the beginning of the work day, or

as tasks/hazards change. Each tailgate safety briefing will be documented on the form

included in the Site Activities Tailgate Health and Safety Briefing Form. This briefing form

documents the tailgate briefing conducted in accordance with the HASP. Personnel who

perform work operations on site are required to attend each briefing and to acknowledge

receipt of each briefing, at least daily.

Verify tailgate

meetings through

documentation.

During construction

SAFETY EQUIPMENT

All employees working on this project must be shown the location and proper use of all

emergency equipment prior to beginning work on the project.

Verify workers

knowledge of safety

equipment location

and use through on-

site monitoring.

During construction

SUBCONTRACTORS

In the event that the subcontractor’s procedures/requirements conflict with requirements

specified in this HASP, the more stringent guidance will be adopted after discussion and

agreement between the subcontractor and project health and safety personnel. Hazards not

listed in this HASP, but known to the subcontractor or known to be associated with the

subcontractor's services, must be identified and addressed to the project or task manager

and construction crew foreman prior to beginning work operations.

The “Subcontractor Acknowledgement Memo” must be signed and dated by the

subcontractor’s management and placed in the project file before they can begin work on

the project. Once the signed memo is received by the project manager, this HASP can be

provided to the subcontractor to use as their own. Subcontractors working at the project

Verify subcontractors

Memo is signed and

included in the

project record

through

documentation.

During construction

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site will need to have this plan with them, and will also need to sign the Subcontractor

HASP receipt signature page.

MM Haz-3 Mitigation Measure Haz-3: If it is necessary to store any chemicals on-site, they would be

managed in accordance with all applicable regulations. Material Safety Data Sheets would

be maintained and kept available on-site, as applicable.

Verify that stored

chemicals have the

MSDS on-site and are

being stored in

accordance with

applicable

regulations through

documentation and

on-site monitoring.

During construction

MM Haz-4 Mitigation Measure Haz-4: In the event that soils suspected of being contaminated (based

on evidence from visual, olfactory, or other means) are removed during excavation

activities along the power line corridor, the excavated soil would be tested and, if

contaminated above hazardous levels, would be contained and disposed of at a licensed

waste facility. The presence of known or suspected contaminated soil would require

testing and investigation procedures to be supervised by a qualified person, as

appropriate, to meet state and federal regulations.

Verify appropriate

testing of potentially

contaminated soils

through

documentation and

on-site monitoring.

During construction

MM Haz-5 Mitigation Measure Haz-5 (Proposed to supersede APM HM-3): PG&E would prepare

and submit a Fire Prevention and Response Plan to the CPUC and to local fire protection

authorities for notification at least 30 days prior to construction. The plan would include

fire protection and prevention methods for all components of the project. The plan would

include procedures to reduce the potential for igniting combustible materials by

preventing electrical hazards, use of flammable materials, and smoking onsite during

construction and maintenance procedures. Project personnel would be directed to park

away from dry vegetation; to equip vehicles with fire extinguishers; not to smoke; and to

Verify required

content in the Fire

Prevention and

Response Plan.

30 days prior to

construction

Verify

implementation of

Fire Prevention and

Response Plan

During construction

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carry water, shovels, and fire extinguishers in times of high fire hazard. The plan would

also include contacting the Santa Barbara County Fire Department when work is

scheduled on Red Flag Days as designated by the National Weather Service.

through

documentation and

on-site monitoring.

Verify coordination

with SBCFD on Red

Flag Days through

documentation.

During operation

Fire prevention

and Response

Plan

FIRE PREVENTION

All employees shall observe all laws, rules, and regulations of fire agencies having

jurisdiction over areas in which they are working (including work areas outside the project

site).

No employee shall perform any operation or action which could result in vegetation or

forest fires.

No employee shall smoke at or in the vicinity of the project site, except in designated areas

that are cleared of vegetation. Employees shall make every attempt to park away from dry

vegetation. Management of any flammable materials at the project site will be in a manner

to minimize fire risk potential.

Verify fire laws are

being followed

through on-site

monitoring.

During construction

FIRE RATINGS

The person in charge shall also be aware of the possibility of increased fire danger during

the time work is in progress. The person will contact the Santa Barbara County Fire

Department when work is scheduled on Red Flag Days as designated by the National

Weather Service.

Additionally, through arrangements with the California Department of Forestry and Fire

Protection (Cal Fire) and the United States Forest Service, PG&E is notified daily during

the California “Fire Season” when next-day fire adjective ratings of Very High or Extreme

Verify Fire Ratings

are followed as

appropriate through

on-site monitoring.

During construction

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are calculated for any adjective rating zone within PG&E’s service territory. The rating

received by PG&E is the prediction of the most severe rating expected for that area the

following day and is used as the rating for that day. This information posted on the PG&E

Intranet at: http://www/fireindex/

The rating is posted by 2100 hours (9:00 p.m.) each day and becomes effective at 0800

hours (8:00 a.m.) the following day.

Effective hours of fire adjective ratings, unless canceled or extended by local authorities,

are as follows:

Very High and Extreme: 0800 until 2 hours after local sunset time, daily.

All other ratings (Low, Medium, and High) do not have specific times noted.

REQUIRED FIRE EQUIPMENT

All personnel working in hazardous fire areas must be equipped with firefighting

equipment such as, but not limited to, shovels, axes, back pumps, fire extinguishers, etc.

Such equipment shall be maintained in good working condition at all times.

Company construction vehicles shall be furnished with the necessary fire prevention

equipment.

Verify personnel

working in

hazardous fire areas

must be equipped

with appropriate

firefighting

equipment through

on-site monitoring.

During construction

APM

WQ-2/HM-2

APM WQ-2/HM-2: Environmental Training and Monitoring Program (ETMP)

development and implementation. Worker environmental awareness will communicate

Verify required

content in the ETMP.

Prior to construction

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environmental issues and appropriate work practices specific to this Project. This

awareness will include spill prevention and response measures and proper BMP

implementation. The SWPPP training will emphasize site-specific physical conditions to

improve hazard prevention (e.g., identification of flow paths to nearest waterbodies) and

will include a review of all site-specific water quality requirements, including applicable

portions of , the Erosion Control and Sediment Transport Plan, Health and Safety Plan,

and PG&E’s Hazardous Substances Control and Emergency Response program.

A monitoring program will also be implemented to ensure that the plans are followed

throughout the construction period. BMPs, as identified in the Project SWPPP and Erosion

Control and Sediment Transport Plan, will also be implemented during the Project to

minimize the risk of an accidental release and to provide the necessary information for

emergency response.

Verify training and

implementation of

ETMP through

documentation and

on-site monitoring.

During construction

MM Hydo-1 Mitigation Measure Hydro-1 (Proposed to supersede APM WQ-1): Following project

approval, PG&E would prepare and implement a SWPPP to minimize construction

impacts on surface and groundwater quality. Implementation of the SWPPP would help

stabilize graded areas and waterways and reduce erosion and sedimentation. The plan

would designate BMPs that would be adhered to during construction activities. Erosion

and sediment control measures, such as straw wattles, water bars, covers, silt fences, and

sensitive area access restrictions (e.g., flagging) would be installed before the onset of

winter rains or any anticipated storm events. Mulching, seeding, or other suitable

stabilization measures would be used to protect exposed areas during construction

activities, as necessary. During construction, measures would be in place to ensure that

contaminants are not discharged from the construction sites.

Verify required

content in the

SWPPP.

Prior to construction

Verify

implementation of

SWPPP through

documentation and

on-site monitoring.

During construction

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MM Hydo-2 Mitigation Measure Hydro-2 (Proposed to supersede APM WQ-3/GM-2): PG&E would

prepare an Erosion Control and Sediment Transport Plan (ECSTP) as an element of the

SWPPP describing BMPs, to be used during construction. The plan would address

construction in or near sensitive areas described in Section 3.5 Biological Resources. BMPs,

where applicable would be designed based on specific criteria from recognized BMP

design guidance manuals. Erosion-minimizing efforts may include measures such as:

Avoiding excessive disturbance of steep slopes

Defining ingress and egress within the project area

Implementing a dust control program during construction

Restricting access to sensitive areas

Using vehicle mats in wet areas

Revegetating disturbed areas where applicable following construction

Proper containment of stockpiled soils (including construction of

berms in areas near water bodies, wetlands, or drainage channels)

Erosion control measures identified in the ECSTP would be installed in an area before

clearing begins during the wet season in that area and before the onset of winter rains or

any anticipated storm events. Temporary measures such as silt fences or wattles, intended

to minimize sediment transport from temporarily disturbed areas, would remain in place

until disturbed areas have stabilized.

The ECSTP would be submitted to the CPUC for review at least 30 days prior to the

commencement of construction. The plan would be revised and updated as needed, and

re-submitted to the CPUC if construction activities evolve to the point that the existing

approved ECSTP does not adequately address the project.

Verify required

content in the ECSTP.

30 days prior to

construction

Verify

implementation of

ECSTP through

documentation and

on-site monitoring.

During construction

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APM Land Use

(LU)-1

Agriculture impacts avoidance. To avoid potential impacts to agriculture, PG&E will work

with farmers and ranchers to conduct its work between their harvest and planting periods

where and whenever possible. In areas containing permanent crops (i.e., grape vines, tree

orchard, etc.) that must be removed and replaced to gain access to poles sites for

construction purposes, PG&E will provide compensation to landowners for crop loss and

other reasonable and associated costs as soon as practicable after completion of

construction. Access across active crop areas will be negotiated with the owners in advance

of any construction activities.

Verify consultation

with local farmers

and ranchers through

documentation.

Verify that

negotiation of crop

compensation is

made through

documentation.

Prior to construction

Verify compensation

for lost crops through

documentation

Post-construction

APM NO-1 APM Noise (NO)-1: Noise minimization with portable barriers. Compressors and other

small stationary equipment will be shielded with portable barriers in proximity to

residential areas.

Verify use of noise

barriers through on-

site monitoring and

documentation

During construction

APM NO-2 APM NO-2: Noise minimization with “quiet” equipment. “Quiet” equipment (i.e.,

equipment that incorporates noise-control elements into the design—compressors have

“quiet” models) will be used during construction whenever possible.

Verify use of “quiet”

equipment through

on-site monitoring

and documentation

During construction

APM NO-3 APM NO-3: Noise minimization through direction of exhaust. Equipment exhaust stacks

and vents will be directed away from buildings

Verify direction of

stacks and vents

through on-site

monitoring

During construction

APM NO-4 APM NO-4: Noise minimization through truck traffic routing. Truck traffic will be Verify truck routes

through

During construction

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routed away from noise-sensitive areas where feasible. documentation and

on-site monitoring

APM NO-5 APM NO-5: Noise disruption minimization through residential notification. PG&E will

coordinate with the City of Lompoc and the County of Santa Barbara to notify residents

that are located near the power lines of the timeframe for the construction activities.

Verify residents have

been notified through

documentation.

Prior to construction

MM Traffic-1 Mitigation Measure Traffic-1 (Proposed to supersede APM TT-1): PG&E would develop

a project-specific TMP, which would be submitted to the CPUC for review at least 30 days

prior to construction. The TMP would conform to the California Joint Utility Traffic

Control Committee’s Work Area Protection and Traffic Control Manual. The TMP would

include the following:

Standard safety practices, including installation of appropriate barriers

between work zones and transportation facilities, placement of

appropriate signage, and use of traffic control devices.

Flaggers and/or signage would be used to guide vehicles through or

around construction zones using proper construction techniques.

Provision that all equipment and materials would be stored in

designated staging areas on or adjacent to the work sites in a manner

that minimizes traffic obstructions and maximizes sign visibility.

Acceptable vehicle speeds on project roadways. Vehicle speeds would

be limited to safe levels as appropriate for all roads, including access

roads and overland routes without existing, posted speed limits.

Verify required

content in the TMP.

30 days prior to

construction

Verify the TMP is

properly

implemented

through

documentation and

on-site monitoring

During construction

Traffic

Management

Plan

TRAFFIC CONTROL

From the edge of the work area (PG&E’s ROW), appropriate traffic signage will be placed

at 1,000-foot intervals along SR 246, up to 3,100 feet to each side of the ROW. Appropriate

traffic signage will also be placed at 350-foot intervals along any crossroad up to 700 feet to

Verify traffic control

through on-site

monitoring.

During construction

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each side of the ROW crossing. Flaggers will be posted to each side of the ROW

TRAFFIC SPEED

PG&E staff and contractors will follow posted vehicle speeds on project roadways. Vehicle

speeds will be limited to safe levels as appropriate for all roads, including access roads and

overland routes without existing, posted speed limits. Vehicle speed on unpaved roads is

limited to 15 miles per hour, except where safety considerations supersede this

requirement, e.g. when heavy loads approach a steep hill.

Verify project traffic

speed through on-site

monitoring.

During construction

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